Justia Massachusetts Supreme Court Opinion Summaries

In this case, the defendant was on trial for murder. During jury deliberations, an argument between two jurors led to allegations of racial bias. The judge conducted a limited inquiry into the matter but did not fully investigate the allegations. The defendant was convicted of murder in the second degree, unlawful possession of a firearm, and unlawful possession of a loaded firearm.The case was initially tried in the Superior Court Department, where the defendant was found guilty. The defendant appealed, and the Appeals Court affirmed the conviction. The Supreme Judicial Court then granted further appellate review.The Supreme Judicial Court of Massachusetts reviewed the case and found that the trial judge's limited inquiry into the allegations of racial bias was insufficient. The court held that the judge should have conducted a more thorough investigation to determine whether the alleged racial bias affected the jury's impartiality. The court emphasized the importance of ensuring a fair and impartial trial, free from racial bias.As a result, the Supreme Judicial Court vacated the defendant's convictions and remanded the case for a new trial. The court's main holding was that the trial judge's failure to adequately investigate the allegations of racial bias created a substantial risk of a miscarriage of justice, warranting a new trial. View "Commonwealth v. Vasquez" on Justia Law

A juvenile was involved in an altercation at the Barnstable District and Juvenile Court, where he was charged with disorderly conduct and assault and battery. The incident was captured on video, showing the juvenile and the victim engaging in a physical fight. The juvenile had a prior continuance without a finding (CWOF) after admitting to sufficient facts for an assault and battery charge.The Juvenile Court adjudicated the juvenile delinquent on both charges and sentenced him to one year of probation for each. The juvenile appealed, arguing that the court lacked jurisdiction over the disorderly conduct charge because a CWOF after an admission to sufficient facts should not count as a prior offense under G. L. c. 119, § 52. The Appeals Court did not review the case as it was transferred to the Supreme Judicial Court.The Supreme Judicial Court held that a CWOF entered after an admission to sufficient facts is sufficient to establish a first offense under § 52. Therefore, the Juvenile Court had jurisdiction over the disorderly conduct charge. The court also found that the evidence was sufficient to support the juvenile's adjudications of delinquency for both disorderly conduct and assault and battery. The court affirmed the adjudications, concluding that the juvenile did not act in self-defense and that his actions met the criteria for disorderly conduct. View "Commonwealth v. Fayad F." on Justia Law

The defendant was convicted of second-degree murder for the killing of Paul Finegan at a backyard birthday party in Springfield. The defendant arrived at the party, where the victim, who was uninvited, became upset upon seeing him. After a brief argument, the defendant shot the victim in the head and fled the scene. The victim was unarmed, and the defendant did not testify at trial. The defense argued that the eyewitnesses were not credible and had been pressured by the police.The case was initially tried in the Superior Court, where the defendant was found guilty of second-degree murder. The defendant filed a motion for a new trial, arguing that a voir dire question asked by the prosecutor during jury selection was improper and deprived him of an impartial jury. The trial judge denied the motion, and the Appeals Court affirmed the conviction and the denial of the motion for a new trial.The Supreme Judicial Court of Massachusetts reviewed the case. The court found that the prosecutor's voir dire question, which asked prospective jurors if they could convict the defendant based on eyewitness testimony without forensic evidence, was improper. However, the court concluded that this error did not create a substantial risk of a miscarriage of justice. The court noted that the evidence against the defendant was overwhelming, and the jury had been properly instructed on the burden of proof and the evaluation of eyewitness testimony. The court affirmed the defendant's conviction and the order denying his motion for a new trial. View "Commonwealth v. Montgomery" on Justia Law

In July 2019, the defendant was charged with one count of possession of child pornography. While at a supermarket, a mother observed the defendant pointing his cell phone at an unusual angle towards her and her daughters. The defendant denied taking photos and showed the mother his phone, which contained several images of clothed women from the waist down. The mother reported the incident to the police. Officer Columbus, who was present at the store, investigated and found numerous images of clothed women on the defendant's phone. Upon further inspection, with the defendant's consent, Columbus discovered images she believed to be child pornography. The defendant admitted to possessing child pornography but claimed he took screenshots to report them to website administrators, though he had not done so.The defendant was found guilty in a bench trial in the District Court and sentenced to six months in a house of correction, suspended for two years. He appealed, arguing that the trial judge erred by allowing a lay witness to testify about the technology used to extract data from his cell phone, which he contended required expert testimony.The Supreme Judicial Court of Massachusetts reviewed the case. The court agreed that the trial judge abused his discretion by allowing some of the contested testimony from Officer McLaughlin, who explained the Cellebrite system used to extract data from the defendant's phone. However, the court concluded that the error was nonprejudicial. The court found that the evidence against the defendant was overwhelming, including testimony from multiple officers and the defendant's own admission. Additionally, the images were properly admitted through McLaughlin's lay testimony. Therefore, the court affirmed the defendant's conviction. View "Commonwealth v. Cronin" on Justia Law

In 2013, an eleven-year-old juvenile was charged with rape of a child by force and assault and battery on a child with substantial injury after allegedly biting his four-year-old cousin's penis. The rape charge was dismissed, and the juvenile was placed on one year of pretrial probation for the reduced charge of simple assault and battery. The juvenile completed probation without incident, and the charge was dismissed. In 2023, the now twenty-two-year-old juvenile, with no other record, petitioned to expunge his record under a statute allowing expungement if the offense is no longer a crime.The Juvenile Court denied the expungement petition. The court found that the offenses of rape of a child by force and assault and battery remain criminal acts, regardless of the age of the perpetrator, and thus do not qualify for expungement under the statute. The court also noted that the juvenile's records were ineligible for time-based expungement due to the serious nature of the offenses.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the Juvenile Court's decision. The court held that the 2018 legislative change, which excluded children under twelve from the Juvenile Court's jurisdiction, did not alter the definition of what constitutes a "crime" for the purposes of expungement under the statute. The court concluded that the relevant inquiry is whether the conduct itself has been decriminalized, not whether the individual can be prosecuted due to age. Since the conduct in question remains criminal, the juvenile's records do not qualify for expungement. View "Commonwealth v. Ambrose A." on Justia Law

The defendant, Tyrone Strong, and three accomplices planned to rob a known drug dealer, Christian Perez, at gunpoint. During the robbery in Fitchburg, Perez was fatally shot. Two accomplices were acquitted in separate trials, and a third had his indictment dismissed. Despite largely circumstantial evidence, a jury found Strong guilty of first-degree murder based on joint venture in a felony-murder with armed robbery as the predicate felony.Following his conviction, Strong filed a motion for a new trial, arguing ineffective assistance of counsel, the "rule of consistency" due to the acquittals and dismissal of his accomplices, and improper jury instructions referencing the dismissed accomplice. The motion judge, not the trial judge, denied the motion.The Supreme Judicial Court of Massachusetts reviewed the case. The court found sufficient evidence to support the conviction, including Strong's presence at the scene, the matching footwear impressions, and items belonging to the victim found in the car Strong was in. The court also found no abuse of discretion in denying the motion for a new trial, as trial counsel's strategy was not manifestly unreasonable. The "rule of consistency" did not apply because joint venture does not require a combination of individuals, and the accomplices were tried separately. The jury instructions were appropriate given the evidence suggesting the dismissed accomplice's involvement.The court affirmed Strong's conviction and the denial of his motion for a new trial, finding no reason to exercise its extraordinary power to vacate the conviction or reduce the verdict. View "Commonwealth v. Strong" on Justia Law

In 2018, the victim ended a five-year relationship with the defendant, who continued to send her text messages and occasionally parked near her home despite her efforts to avoid him. Two years later, the defendant sent the victim two text messages expressing anger and hurt. The next day, after an encounter at a fundraiser, the defendant sent another text message threatening to punch the victim.The defendant was convicted of violating the threatening to commit a crime statute in the New Bedford Division of the District Court Department. The Appeals Court affirmed the conviction, but the Supreme Judicial Court granted further appellate review.The Supreme Judicial Court of Massachusetts reviewed the case and found that the jury was not instructed to find that the defendant acted with the required mens rea, as established by the U.S. Supreme Court in Counterman v. Colorado. The Court held that the conviction violated the First Amendment because the jury was not instructed to find that the defendant consciously disregarded a substantial risk that his communication would be viewed as threatening violence. The Court also concluded that the threatening to commit a crime statute is not facially overbroad when construed to require proof of recklessness. The Court vacated the defendant's conviction and remanded the case for a new trial, allowing the Commonwealth to retry the defendant with proper jury instructions. View "Commonwealth v. Cruz" on Justia Law

In 1999, the defendant admitted to sufficient facts to support a finding of guilty for distributing a class A substance. He later sought to withdraw this admission, claiming his plea counsel failed to inform him that it would lead to mandatory deportation. The defendant, a legal permanent resident since 1994, argued that he would have insisted on going to trial had he known the immigration consequences, citing his strong ties to the United States, including his American citizen wife and children, and his consistent employment as a welder.The defendant's initial motion for a new trial was denied due to the absence of an affidavit from his plea counsel. He then filed a renewed motion with the necessary affidavit, which was also denied by a District Court judge after a non-evidentiary hearing. The judge concluded that while the plea counsel was ineffective, the defendant failed to demonstrate prejudice. The Appeals Court affirmed this decision.The Supreme Judicial Court of Massachusetts reviewed the case, focusing on whether the defendant established prejudice from his counsel's ineffectiveness. The court found that the motion judge improperly assessed the defendant's claim by not applying the reasonable person standard and by making credibility determinations about the defendant's assertion that he would have gone to trial. The court vacated the denial of the renewed motion and remanded the case for further findings on whether the defendant's ties to the United States constituted special circumstances and whether a reasonable person in his situation would have chosen to go to trial if properly advised. View "Commonwealth v. Torres" on Justia Law

An undercover police officer, without a warrant, used his cell phone to make audio-visual recordings while purchasing drugs from the defendant. These recordings captured both the audio of their conversations and video footage of the defendant. The defendant was subsequently charged with multiple counts of drug distribution and moved to suppress the recordings, arguing they were unlawful interceptions under the wiretap act.The Superior Court judge partially granted the motion, suppressing the audio but allowing the video footage to be used as evidence if shown silently. Both parties sought interlocutory appeal. The Appeals Court ruled that both the audio and video components must be suppressed under the wiretap act. The Commonwealth then sought further appellate review.The Supreme Judicial Court of Massachusetts reviewed the case and held that the wiretap act's suppression remedy extends to both the audio and video components of the recordings. The court reasoned that the video footage, even without audio, contains information about the identity of the parties and the existence of the communication, which falls under the statute's definition of "contents." Therefore, the entire recording must be suppressed to align with the legislative intent of protecting privacy and deterring unauthorized surveillance.The court affirmed the suppression of the audio and reversed the decision allowing the video footage, ordering that both components be suppressed. View "Commonwealth v. Du" on Justia Law

On August 14, 2018, Yashua Amado, Darrell Smith, and Jerome Smith were shot while sitting in Amado's car on Deering Road in Mattapan. Amado was killed, and Darrell and Jerome sustained non-life-threatening injuries. The shooter was never identified. Dewane M. Tse was indicted for first-degree murder and two counts of armed assault with intent to murder, accused of participating in a joint venture by following the victims and driving the shooter to and from the crime scene.In the Superior Court, a jury convicted Tse of first-degree murder based on deliberate premeditation regarding Amado and armed assault with intent to murder Darrell. Tse was acquitted of the charge related to Jerome. Tse's motions for required findings of not guilty were denied by the trial judge, who sentenced him to life without parole for the murder and a concurrent term for the assault. Tse appealed, arguing insufficient evidence to prove he knowingly participated in the shooting or shared the shooter's lethal intent.The Supreme Judicial Court of Massachusetts reviewed the case. The court found insufficient evidence to prove beyond a reasonable doubt that Tse knew of or shared the shooter's lethal intent. The court noted that the evidence, including GPS data, cell site location information, and video footage, did not establish Tse's knowledge or intent to kill. The court emphasized that the Commonwealth's argument relied on speculative assertions about Tse's maneuvering of the vehicle, which was insufficient to prove shared lethal intent.The court reversed Tse's convictions for first-degree murder and armed assault with intent to murder, set aside the verdicts, and remanded the case to the Superior Court for entry of required findings of not guilty. View "Commonwealth v. Tse" on Justia Law