Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed the ruling of the superior court entering declaratory judgment in favor of the city council of Springfield and held that the city council may reorganize the Springfield police department based on the plain language of the relevant statutes and city ordinances.At issue was whether the city council had the authority to reorganize the police department to be headed by a five-person board of police commissioners rather than a single commission under the provisions of the Springfield city charter passed in accordance with Mass. Gen. Laws ch. 43, 46-55. After the mayor refused to implement the city council's ordinance restructuring the police department the city council brought this action. The court entered a judgment declaring that the mayor must appoint qualified individuals to serve on the board. The Supreme Judicial Court affirmed, holding (1) the ordinance was clearly within the scope of the city council's power to reorganize municipal departments; and (2) there was no separation of powers problem in this case. View "City Council of Springfield v. Mayor of Springfield" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on a theory of extreme atrocity or cruelty for the killing of his wife, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Judicial Court held (1) the prosecutor did not improperly exercise a peremptory challenge to strike a male juror; (2) the trial judge did not abuse her discretion in connection with certain evidentiary decisions; (3) the prosecutor's challenged statements in his closing argument did not create a substantial likelihood of a miscarriage of justice; (4) the jury instruction on mental impairment was sufficient; (5) the denial of Defendant's motion for a new trial did not constitute an abuse of discretion; and (6) this Court declines to exercise its authority under Mass. Gen. Laws 278, 33E, to order a new trial or a reduction in the verdict. View "Commonwealth v. Huang" on Justia Law

The Supreme Judicial Court affirmed the order of the denying Defendant's motion to suppress evidence obtained after surveillance was conducted at Defendant's apartment building via a hidden video camera placed on a nearby public utility pole, holding that although the pole camera surveillance constituted a warrantless search under article 14 of the Massachusetts Declaration of Rights, it was nevertheless constitutional.Defendant was indicted on child pornography charges. After the surveillance at issue in this case took place but before the superior court decided Defendant's motion to suppress, Commonwealth v. Mora, 485 Mass. 360 (2020) was decided. In Mora, the Supreme Judicial Court decided that pole camera surveillance could, under certain circumstances, constitute a search requiring a warrant. After the motion to suppress in this case was decided, Defendant brought an interlocutory appeal. The Supreme Judicial Court affirmed the order denying Defendant's motion to suppress, holding (1) the pole camera surveillance constituted a search; but (2) probable cause existed to conduct the pole camera surveillance prior to the time the search began. View "Commonwealth v. Comenzo" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on the theories of deliberate premeditation and extreme atrocity or cruelty and assault and battery by means of a dangerous weapon, holding that there was no reversible error in the proceedings below.Defendant was sentenced on the murder conviction to a term of life in State prison, to be served after his sentence for assault and battery. On appeal, Defendant filed a motion for a new trial based on ineffective assistance of counsel. The trial judge denied the motion. The Supreme Judicial Court affirmed, holding that there was no reversible error in the trial proceedings and that there was no reason for this Court to exercise its authority under Mass. Gen. Laws ch. 278, 33E to grant a new trial or to reduce or set aside the verdict of murder in the first degree. View "Commonwealth v. Denson" on Justia Law

The Supreme Judicial Court affirmed the superior court judge denying Defendant's motion to suppress a video recording Defendant published to his social media account that showed an individual seen from the chest down holding what appeared to be a firearm, holding that no search in the constitutional sense occurred.After accepting a friend request from an undercover police officer, Defendant published the video at issue to his social media account. The officer made a recording of the posting, and that recording was used in the criminal proceedings against Defendant. The trial judge concluded that no search had occurred and denied Defendant's motion to suppress. The Supreme Court affirmed, holding that Defendant did not retain a reasonable expectation of privacy in his social media stories. View "Commonwealth v. Carrasquillo" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction for two counts of armed assault with intent to murder and other crimes, holding that denying superior court defendants the statutory right to a defendant-capped plea does not violate equal protection principles under either the Federal or State Constitutions.Defendant was charged, pleaded guilty, and was sentenced in the superior court. Defendant sought to withdraw his plea on the basis of a facial challenge to the procedural scheme laid out in Mass. Gen. Laws ch. 278, 18 and rule 12(c)(4)(A), arguing that denying superior court defendants the statutory right to a defendant-capped plea violates constitutional equal protection principles. The Supreme Judicial Court affirmed, holding that the procedural scheme of Mass. Gen. Laws ch. 278, 18 and Mass. R. Crim. P. 12 survives rational basis scrutiny. View "Commonwealth v. Roman" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction for simple assault and battery, holding that while Defendant's bench trial, conducted partly via Zoom, did not violate Defendant's constitutional rights, this opinion sets forth guidelines to be followed when remote bench trials are contemplated in criminal cases.Defendant's bench trial was in the midst of the COVID-19 pandemic over an Internet-based video conferencing platform. On appeal, Defendant argued that his trial violated his constitutional rights to confront the witnesses against him, to be present at trial, to have a public trial, and to have effective assistance of counsel. The Supreme Judicial Court affirmed, holding that Defendant was not prejudiced by his appearance over Zoom at his trial and did not receive ineffective assistance of counsel. Because the Court recognized that a criminal defendant's constitutional rights may be implicated when critical stages of court proceedings are conducted remotely, the Court provided guidance in this opinion to trial courts that offer defendants virtual or partly virtual bench trials during the COVID-19 pandemic. View "Commonwealth v. Curran" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions entered upon his conditional guilty plea to the charges of possession of a firearm without a license and possession of a large capacity feeding device, holding that the superior court did not err in denying Defendant's motion to suppress.On appeal, Defendant argued that the officers that stopped him after a routine traffic stop and then conducted a pat frisk did not have reasonable suspicion that he might be armed and dangerous. The Supreme Judicial Court affirmed the order denying Defendant's motion to suppress, holding that the facts, when taken together, warranted a reasonably prudent person's belief that Defendant was armed and dangerous. View "Commonwealth v. Sweeting-Bailey" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court judge denying Plaintiffs' second request for a preliminary injunction, holding that there was no error.Plaintiffs, a class of inmates in Department of Correction (DOC) facilities, brought this complaint alleging that the conditions of their confinement during the COVID-19 pandemic constituted cruel and unusual punishment under the Eighth Amendment and seeking to enjoin the DOC to use various measures to reduce the incarcerated population. After the class was certified Plaintiffs filed a second emergency motion for a preliminary injunction seeking an immediate reduction in the incarcerated population. The motion judge denied Plaintiffs' second motion for preliminary relief. The Supreme Judicial Court affirmed, holding that Plaintiffs were unlikely to prevail on their Eighth Amendment claim, and therefore, the superior court did not err in denying their second motion for preliminary relief. View "Foster v. Commissioner of Correction" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court denying Petitioner's petition for relief pursuant to Mass. Gen. Laws ch. 211, 3, holding that the single justice did not err in denying relief.Petitioner, who was awaiting trial on two counts of murder in the first degree and related firearm offenses, brought this action challenging the trial court's grant of the Commonwealth's motion for a protective order prohibiting defense counsel from providing Petitioner with copies of certain discovery materials. In his petition, Petitioner argued that the order would violate his constitutional right to prepare his defense. The single justice denied the petition without holding a hearing. The Supreme Judicial Court affirmed, holding that Petitioner failed to establish that the remedy of direct appeal would be inadequate in his case. View "Torres v. Commonwealth" on Justia Law