Justia Massachusetts Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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The Supreme Judicial Court affirmed the order of the trial court denying Defendant's motion for reduction of the verdict or for a new trial, holding that principles of direct estoppel precluded another review in this case.Defendant was convicted of murder in the second degree and battery by means of a dangerous weapon causing serious bodily injury. The appeals court affirmed. More than nine years after trial, Defendant filed a motion to reduce the verdict of murder in the second degree or to grant a new trial. The superior court judge concluded that principles of estoppel precluded resisting issues that substantially had been decided previously. The Supreme Judicial Court affirmed, holding that direct estoppel precluded further consideration of the issues Defendant raised on appeal. View "Commonwealth v. Arias" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court vacated and set aside the order of the superior court judge denying Defendant's motion to suppress the fruits of a search of Defendant's home, holding that the warrantless investigatory review of the video footage taken from use of a body-worn camera that was unrelated to the domestic disturbance call in this case was unconstitutional.As he responded to a call about a domestic disturbance at Defendant's home, a police officer, who was equipped with a body-worn camera, created a digital recording of the encounter. The video footage was later retrieved and reviewed in connection with an ongoing independent investigation of Defendant for firearms offenses. Defendant was indicted on firearms-related offenses and moved to suppress the video recording from the body-worn camera and the fruits of the search warrant. The motion judge denied the motion. The Supreme Judicial Court vacated the order denying the motion to suppress, holding that (1) the use of the body-worn camera within the home was not an unconstitutional search; but (2) the later warrantless investigatory review of the video footage violated Defendant's constitutional right to be protected from unreasonable searches. View "Commonwealth v. Yusuf" on Justia Law

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The Supreme Judicial Court held that the Commissioner of Correction's exercise of the "commissioner's certification" provision in Mass. Gen. Laws ch. 18(a) to retain K.J. at Bridgewater State Hospital violated article 30 of the Massachusetts Declaration of Rights.K.J., an adult man who faced criminal charges in the district court and the superior court, was committed involuntarily to Bridgewater. The commitment was subsequently extended. This appeal concerned the medical director of Bridgewater's most recent petition to have K.J. again recommitted for one year under section 18(a). The judge found that K.J. did not require strict custody and therefore, as required by section 18(a), issued an order committing K.J. to a lower security Department of Mental Health (DMH) facility. Despite that order, the Commissioner exercised the "commissioner's certification" provision in section 18(a) to retain K.J. at Bridgewater. The Supreme Judicial Court ordered that K.J. be transferred to a DMH facility, holding (1) the commissioner's certification provision of section 18(a) violates article 30; and (2) the remainder of section 18(a) is capable of separation. View "K.J. v. Superintendent of Bridgewater State Hospital" on Justia Law

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The Supreme Judicial Court vacated Defendant's conviction of armed assault with intent to rob as duplicative of his felony murder conviction and otherwise affirmed Defendant's convictions, holding that the evidence supporting the conclusion that Defendant attempted to commit an armed robbery was the same as the evidence establishing that Defendant committed an armed assault with intent to rob.After a jury trial, Defendant was convicted of murder in the first degree on the theory of felony murder, with the predicate offense of armed robbery, armed assault with intent to rob, and armed home invasion. The Supreme Judicial Court vacated Defendant's convictions of armed assault with intent to rob as duplicative of the predicate felony of armed robbery and declined to exercise its authority under Mass. Gen. Laws ch. 278, 33E to grant a new trial or reduce or set aside the verdict of murder in the first degree, holding that the conviction of armed assault with intent to rob must be vacated as duplicative of Defendant's felony-murder conviction. View "Commonwealth v. Quiles" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court vacated Defendants' convictions for murder in the first degree on a theory of joint venture, holding that it was an abuse of discretion for the judge not to require the Commonwealth to provide a race-neutral reason for its challenge of at least one African-American juror and that sexual orientation is a protected class for purposes of a Batson-Soares challenge.Defendants, Antwan Carter and Daniel Pickney, appealed from their convictions, arguing that the trial judge erred in allowing the Commonwealth's peremptory challenges of five prospective jurors - four based on the prospective jurors' race and one based on a juror's sexual orientation. The Supreme Judicial Court reversed, holding (1) Defendants made the limited showing necessary to make a prima facie case of racial discrimination with respect to the challenge of one juror, and the judge's decision constituted structural error for which prejudice is presumed; and (2) while sexual orientation is a protected class Defendants did not satisfy their burden of production under the first step of the Batson-Soares inquiry with respect to that particular challenge. View "Commonwealth v. Carter" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court reversed the order of the superior court concluding that the Commonwealth's exercise of its statutory right to demand a jury trial violated Petitioner's substantive due process rights and allowing Petitioner's motion for a bench trial, holding that the judge erred in concluding that Petitioner's substantive due process rights were violated.A jury found Petitioner to be a sexually dangerous person, and Petitioner was committed to the Massachusetts Treatment Center. Petitioner later filed a motion pursuant to Mass. Gen. Laws ch. 123A, 9 for discharge from civil commitment as a sexually dangerous person. A jury trial in 2018 resulted in a mistrial, and the matter was rescheduled for retrial in 2020. The trial, however, was continued indefinitely because of the COVID-19 pandemic and the suspension of jury trials in the state. A superior court judge granted Petitioner's motion to proceed with a bench trial, concluding that it was unconstitutional for the Commonwealth to exercise its right to demand a jury trial. The Commonwealth appealed. The Supreme Judicial Court reversed, holding that continuing commitment after a single mistrial where Petitioner was previously found to be sexually dangerous did not violate Petitioner's due process rights and did not require that Petitioner be given the opportunity to seek release pending trial. View "In re LeSage" on Justia Law

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The Supreme Judicial Court affirmed the order of the single justice of the appeals court denying Defendant's motion to stay his sentence pending appeal of his motion for a new trial, holding that Defendant presented a serious flight risk.Defendant was convicted of murder in the first degree and sentenced to a term of life imprisonment. On October 26, 2020, Defendant filed a second motion for a new trial and a motion to stay the execution of his sentence, seeking release due to COVID-19 concerns. The superior court denied the motion to stay, concluding that Defendant did not satisfy any of the factors set forth in Commonwealth v. Nash, 486 Mass. 394 (2020). Thereafter, Defendant filed a motion to stay with a single justice in the appeals court. The single justice concluded that Defendant was a flight risk and that COVID-19 concerns did not support a different result because Defendant had already been vaccinated against COVID-19. The Supreme Judicial Court affirmed, holding that the single justice properly denied Defendant's motion to stay his sentence pending appeal of his motion for a new trial. View "Commonwealth v. McDermott" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on a theory of deliberate premeditation and declined relief pursuant to Mass. Gen. Laws ch. 278, 33E, holding that there was no reason to order a new trial, reduce the verdict, or grant any other relief.Specifically, the Supreme Judicial Court held (1) the trial judge did not err in declining to instruct the jury on voluntary manslaughter; (2) the trial judge did not erred in allowing a Boston police detective to testify about the contents of a certain record of the United States Customs and Border Protection agency that he saw on a computer screen at Logan Airport, but the error was not prejudicial; (3) the trial judge's instruction to the jury in response to Defendant's closing argument was not prejudicial; and (4) the prosecutor's remarks during closing arguments did not rise to the level of prejudicial error. View "Commonwealth v. Brea" on Justia Law

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The Supreme Judicial Court affirmed the convictions of Josiah Zachery and Donte Henley of murder in the first degree and Zachery's convictions of assault by means of a dangerous weapon and carrying a firearm without a license, holding that there was no reversible error.Specifically, the Supreme Judicial Court held (1) the motion judge did not err in denying Zachery's motion to suppress evidence obtained during an investigatory stop, a warrantless search of his CharlieCard, and a search of his cell phone pursuant to a search warrant; (2) the judge did not abuse his discretion in denying Zachery's motion to sever his case from Henley's; (3) the judge did not err in admitting evidence of prior misconduct that connected Henley to an earlier shooting; and (4) there was no other prejudicial error. View "Commonwealth v. Henley" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court vacated the denial of Defendant's Mass. R. Crim. P. 30(a) motion seeking to vacate his remaining sentences after he was paroled from his life sentence for murder and remanded the matter to the superior court for a hearing, holding that the motion judge failed to consider the specific circumstances and unique characteristics of Defendant as a juvenile.In 1996, Defendant, who was seventeen, committed crimes that resulted in his guilty plea to murder in the second degree, armed assault with intent to murder, and illegal possession of a firearm. Defendant was sentenced to life imprisonment for murder and two sentences of five to seven years' imprisonment for the assaults to run concurrent to each other but consecutive to the life sentence. After Defendant was paroled from his life sentence he moved to vacate the remaining sentences and for resentencing under Rule 30(a). The motion judge denied the motion. The Supreme Judicial Court remanded the matter to consider whether Defendant's sentences comported with article 26 of the Massachusetts Declaration of Rights, holding (1) 120 Code Mass. Regs. 200.08 distinguishes parole for life sentences from other sentences and is therefore invalid; and (2) because Defendant already served the aggregate minimum of his sentences, he was immediately entitled to a parole hearing. View "Commonwealth v. Sharma" on Justia Law