Justia Massachusetts Supreme Court Opinion Summaries

The case involves a defendant who was convicted of multiple charges following an altercation involving a woman and three men, including the defendant and the victim. The defendant was found guilty of assault with intent to maim, mayhem, assault and battery by means of a dangerous weapon (knife) causing serious bodily injury, assault and battery by means of a dangerous weapon (shod foot), two counts of assault and battery, and misleading a police officer. The incident occurred after the defendant drove the intoxicated woman to her home, where a violent confrontation ensued with the victim.In the Superior Court, the defendant was convicted by a jury on the aforementioned charges. The defendant appealed, raising three issues: the exclusion of Adjutant evidence, the sufficiency of evidence for the conviction of misleading a police officer, and the duplicative nature of certain convictions. The Supreme Judicial Court granted direct appellate review.The Supreme Judicial Court of Massachusetts reviewed the case and held that the trial judge did not abuse his discretion in excluding the Adjutant evidence related to the defendant's self-defense claim and declined to extend the Adjutant rule to defense of another. The court found insufficient evidence to support the conviction of misleading a police officer, as the defendant's simple denial did not demonstrate specific intent. The court also determined that the convictions for assault with intent to maim and assault and battery by means of a dangerous weapon causing serious bodily injury were duplicative of the mayhem conviction, and one of the assault and battery convictions was duplicative of the assault and battery by means of a dangerous weapon conviction. Consequently, the court vacated the convictions for misleading a police officer, assault with intent to maim, assault and battery by means of a dangerous weapon causing serious bodily injury, and one count of assault and battery, while affirming the remaining convictions and remanding the case for resentencing. View "Commonwealth v. Rateree" on Justia Law

A Cambridge police officer observed a black Mazda sedan with an unilluminated rear license plate and initiated a traffic stop. The driver, Natnael Zemene, and two passengers were removed from the vehicle for an inventory search, which revealed a bottle of tequila and a box of ammunition. During a subsequent pat frisk, a firearm was found under Zemene's foot. Zemene admitted ownership of the firearm and was arrested.Zemene was charged with possession of ammunition without a license, carrying a firearm without a license, carrying a loaded firearm without a license, unlicensed operation of a motor vehicle, and two civil motor vehicle infractions. He was found guilty of carrying a firearm without a license but not guilty of the other charges. The trial judge denied his motion for a required finding of not guilty and sentenced him to eighteen months in a house of correction. Zemene's post-trial motions were denied, and his sentence was stayed pending appeal.The Supreme Judicial Court of Massachusetts reviewed the case. Zemene argued that retrial on the charge of carrying a firearm without a license would violate the double jeopardy clause. The court held that the relevant legal change occurred with its decision in Commonwealth v. Guardado, not the U.S. Supreme Court's decision in New York State Rifle & Pistol Ass'n v. Bruen. Therefore, the double jeopardy clause did not bar retrial. The court affirmed the single justice's denial of Zemene's petition for relief. View "Zemene v. Commonwealth" on Justia Law

The defendant was observed by a state trooper driving at a high speed and was stopped. During the stop, the trooper noticed the defendant making movements that suggested he might be armed. The trooper conducted a patfrisk and found a firearm in the defendant's jacket pocket. The defendant was charged with carrying a firearm without a license and other related offenses. He filed a motion to suppress the firearm and a statement he made during the stop, which was denied. The defendant was convicted and sentenced to eighteen months in a house of correction.The defendant's trial occurred after the Supreme Court's decision in New York State Rifle & Pistol Ass'n v. Bruen but before the Massachusetts Supreme Judicial Court's decision in Commonwealth v. Guardado. The trial court denied the defendant's posttrial motion for a required finding of not guilty, and the defendant appealed. The Supreme Judicial Court granted direct appellate review.The Supreme Judicial Court of Massachusetts held that the defendant is entitled to a new trial. The court determined that the appropriate remedy for defendants convicted under G. L. c. 269, § 10 (a) after Bruen but before Guardado I is a new trial, not a required finding of not guilty. The court reasoned that the Commonwealth could not have known it needed to prove the absence of a firearms license at the time of the defendant's trial, as Guardado I had not yet been decided. The court also affirmed the denial of the defendant's motion to suppress the firearm, finding that the trooper had reasonable suspicion to conduct the patfrisk and probable cause to seize the firearm. The case was remanded for a new trial. View "Commonwealth v. Crowder" on Justia Law

The defendant was convicted of first-degree murder for killing his wife after discovering text messages between her and another man. The defense argued mental impairment, supported by an expert forensic psychiatrist's testimony. The defendant appealed his conviction and the denial of his motion for a new trial, claiming ineffective assistance of counsel for not pursuing a heat of passion defense and for inadequate preparation of the expert witness.The Superior Court jury found the defendant guilty, and the motion for a new trial was denied by another judge. The motion judge held that trial counsel's strategic decision to focus on the mental impairment defense was not manifestly unreasonable and that any prejudice from the expert's unprepared answer was mitigated by subsequent testimony.The Supreme Judicial Court of Massachusetts reviewed the case and found no abuse of discretion in the motion judge's decision. The court held that trial counsel's decision not to pursue a heat of passion defense was reasonable given the weak evidence supporting it and the stronger mental impairment defense. The court also found that any error in preparing the expert witness did not create a substantial likelihood of a miscarriage of justice. The court affirmed the conviction and the denial of the motion for a new trial. View "Commonwealth v. Fratantonio" on Justia Law

The defendant was convicted of first-degree murder and unlawful possession of a firearm. The murder occurred on July 4, 2018, when the victim was shot while watching fireworks with his wife. The shooter was a passenger in a Volkswagen driven by Michael Carleton. The car was registered to Carleton's girlfriend, and the defendant's fingerprints and DNA were found in the car. The shooter was seen entering the defendant's mother's apartment building immediately after the shooting.In the Superior Court, the defendant's pretrial motion to suppress evidence was denied, and he was subsequently convicted by a jury. The defendant appealed, raising several arguments, including insufficient evidence of identity, improper statements by the prosecutor, and errors in jury instructions.The Supreme Judicial Court of Massachusetts reviewed the case. The court found that there was sufficient evidence to identify the defendant as the shooter, including video footage, forensic evidence, and the defendant's connection to the car and the apartment building. The court also determined that the prosecutor's statements during opening and closing arguments, while forceful, did not improperly appeal to the jury's emotions or shift the burden of proof.The court acknowledged an error in the jury instruction regarding extreme atrocity or cruelty but concluded that it did not result in a substantial likelihood of a miscarriage of justice because the defendant was also convicted on the theory of deliberate premeditation. Additionally, the court found that the failure to instruct the jury on the Commonwealth's burden to prove the defendant did not have a firearms license warranted vacating the firearm conviction and remanding for a new trial on that charge.The court affirmed the first-degree murder conviction and vacated the firearm conviction, remanding it for a new trial. View "Commonwealth v. Phillips" on Justia Law

The defendant, a New Hampshire resident, was arrested in Massachusetts on November 8, 2021, for operating a motor vehicle under the influence of alcohol following a collision. During a search of his vehicle, a handgun and ammunition were found. The defendant did not have a Massachusetts nonresident firearm license and was charged with unlawful possession of a firearm under G. L. c. 269, § 10 (a). He moved to dismiss the charge, arguing that the nonresident licensing scheme violated his Second Amendment rights, relying on the U.S. Supreme Court's decision in New York State Rifle & Pistol Ass'n v. Bruen.The District Court judge allowed the motion to dismiss, concluding that the nonresident licensing scheme was unconstitutional as applied to the defendant. The judge found that the scheme violated the Second Amendment by imposing discretionary licensing requirements on nonresidents. The Commonwealth appealed, and the Supreme Judicial Court of Massachusetts granted direct appellate review.The Supreme Judicial Court of Massachusetts held that the Commonwealth's prior nonresident firearm licensing scheme, which allowed the State police colonel discretion to issue or deny licenses, violated the Second Amendment under the Bruen decision. The court noted that such discretionary "may issue" regimes are presumptively invalid and not supported by historical tradition. The court also found that the impermissible portions of the statute could not be severed from the remainder, rendering the entire scheme unconstitutional. Consequently, the court affirmed the dismissal of the charge against the defendant. View "Commonwealth v. Donnell" on Justia Law

The defendant, a New Hampshire resident, was involved in a vehicle accident in Massachusetts and was found in possession of an unlicensed firearm. He was charged with unlawful possession of a firearm and ammunition. The defendant filed a motion to dismiss, arguing that the Commonwealth's nonresident firearm licensing scheme violated his Second Amendment rights in light of the Supreme Court's decision in New York State Rifle & Pistol Ass'n v. Bruen. The motion judge allowed the motion to dismiss, and the Commonwealth appealed.The Supreme Judicial Court of Massachusetts reviewed the case. The court first determined that the defendant lacked standing to bring an as-applied challenge to the Commonwealth's nonresident firearm licensing scheme because he had not applied for and been denied a license under that scheme. The court then considered the merits of a facial challenge to the scheme.The court held that the Commonwealth's nonresident firearm licensing scheme is consistent with the Second Amendment. The scheme's purpose is to restrict access to firearms by demonstrably dangerous persons, which is consistent with the nation's historical tradition of firearm regulation. The court also found that the scheme's "shall issue" licensing regime, which requires nonresidents to meet specific criteria to obtain a license, is analogous to historical regulations such as surety and going armed laws.Additionally, the court held that the scheme does not violate the Fourteenth Amendment rights to travel and to equal protection. The differences in the treatment of resident and nonresident license applicants, such as license duration and processing times, are rationally related to the legitimate state interest of ensuring public safety.The Supreme Judicial Court reversed the motion judge's order allowing the defendant's motion to dismiss, upholding the constitutionality of the Commonwealth's nonresident firearm licensing scheme. View "Commonwealth v. Marquis" on Justia Law

The case involves the defendant, David Roman, who was convicted of murder in the first degree for the killing of Joseph Stanick. On May 9, 2015, a police officer found Stanick's dead body at his residence. Roman admitted to killing Stanick but claimed it was in self-defense. The victim had suffered seventy-six stab wounds, and Roman was later indicted and convicted by a jury of murder in the first degree based on extreme atrocity or cruelty.The case was initially tried in the Superior Court Department, where Roman was convicted. He filed a motion to reduce the verdict, which was also considered and denied by the same court. Roman appealed the conviction and the denial of his motion, arguing that the evidence was insufficient to support his conviction and that various errors by his counsel, the Commonwealth, and the judge required reversal. He also requested the court to exercise its power under G. L. c. 278, § 33E, to reduce the verdict.The Supreme Judicial Court of Massachusetts reviewed the case. The court affirmed Roman's conviction and declined to reduce the verdict. The court found that the evidence presented at trial was sufficient to support the conviction of murder in the first degree. The court also addressed and dismissed Roman's claims of ineffective assistance of counsel, improper admission of evidence, and prosecutorial misconduct. The court concluded that any errors in the trial proceedings did not result in a substantial likelihood of a miscarriage of justice. View "Commonwealth v. Roman" on Justia Law

In the early morning of October 23, 2013, Colleen Ritzer, a Danvers High School math teacher, was found dead in the woods outside the high school. She had been raped, strangled, and stabbed. The defendant, a fourteen-year-old student in her class, was convicted by a Superior Court jury of first-degree murder, aggravated rape, and armed robbery. The primary issue at trial was whether the defendant lacked criminal responsibility due to mental illness.The defendant appealed, arguing that the trial judge impeded his ability to present his defense. He raised several issues: the exclusion of expert testimony on brain scans, limitations on expert testimony regarding his statements, improper cross-examination of defense experts, forced disclosure of psychological test data, the use of suppressed statements by the Commonwealth's expert, the denial of a jury instruction on adolescent brain development, insufficient evidence for the aggravated rape and armed robbery convictions, the denial of a motion to suppress evidence, improper prosecutorial conduct in closing arguments, the denial of a change of venue due to pretrial publicity, and the proportionality of his sentence under the Massachusetts Declaration of Rights.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the convictions. The court held that the exclusion of the brain scan evidence was within the judge's discretion due to its limited probative value and potential for unfair prejudice. The limitations on expert testimony were also upheld, since the defendant was able to present sufficient evidence of his mental state. The court found no abuse of discretion in the cross-examination of defense experts or the disclosure of psychological test data. The use of the suppressed statements by the Commonwealth's expert did not warrant exclusion of the testimony. The court also found no error in the denial of the jury instruction on adolescent brain development, the sufficiency of the evidence for the aggravated rape and armed robbery convictions, the denial of the motion to suppress, or the prosecutor's closing arguments. The court concluded that the defendant was not entitled to a change of venue and that his sentence was not disproportionate under the Massachusetts Declaration of Rights. View "Commonwealth v. Chism" on Justia Law

The defendant was charged with three counts: second-degree murder, manslaughter while operating a motor vehicle under the influence of alcohol, and leaving the scene of personal injury resulting in death. The trial lasted over two months, involving extensive evidence and numerous witnesses. After deliberating for several days, the jury sent three notes to the judge indicating they were unable to reach a unanimous verdict. The judge declared a mistrial based on the jury's final note, which stated that further deliberation would be futile and would force jurors to compromise their deeply held beliefs.The defendant filed a motion to dismiss, arguing that posttrial accounts from several jurors indicated they had unanimously agreed she was not guilty on two of the three charges and were deadlocked only on the remaining charge. The trial judge denied the motion, reasoning that no verdict was announced in open court, and thus, there was no acquittal. The judge also rejected the request for a posttrial juror inquiry, stating that it would involve an impermissible inquiry into the substance of the jury's deliberations.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the trial judge's decision. The court held that the trial judge acted within her discretion in declaring a mistrial based on manifest necessity, given the jury's repeated statements of deadlock and the risk of coercion in further deliberations. The court also concluded that posttrial juror accounts could not retroactively alter the trial's outcome, as no verdict was returned and affirmed in open court. Therefore, the defendant's motion to dismiss and request for a posttrial juror inquiry were properly denied. View "Read v. Commonwealth" on Justia Law