Justia Massachusetts Supreme Court Opinion Summaries

The defendant was convicted of murder in the first degree, armed assault with intent to murder, and assault and battery by means of a dangerous weapon. The charges stemmed from his role as the getaway driver after a shooting in Charlestown, Boston, where two men in hooded sweatshirts shot Ryan Morrissey and Jamie Lawton outside a convenience store, killing Morrissey and seriously injuring Lawton. Witnesses saw the assailants flee on foot and enter a car driven by the defendant. The car was later identified as belonging to the defendant's mother.In the Superior Court, the defendant was tried jointly with two alleged assailants, Danilo Soto and Alexander Soto, who were acquitted by the jury. The defendant was found guilty on all charges. He appealed, arguing insufficient evidence to prove he was the driver and that he shared the assailants' lethal intent. He also challenged the trial judge's decisions on jury selection and the admissibility of expert testimony.The Supreme Judicial Court of Massachusetts reviewed the case. The court found sufficient evidence to establish that the defendant was the getaway driver. However, it concluded that there was insufficient evidence to prove that the defendant knew of or shared the assailants' lethal intent. The court emphasized that the evidence did not show the defendant knew the assailants were armed or intended to kill the victims. Consequently, the court reversed the defendant's convictions of murder in the first degree, armed assault with intent to murder, and assault and battery by means of a dangerous weapon, and remanded the case for entry of a required finding of not guilty. View "Commonwealth v. Baez" on Justia Law

The defendant was convicted of reckless endangerment of a child and witness intimidation after attacking her twelve-year-old son. The incident began with an argument about the son's dental braces, leading the defendant to contemplate suicide. The next morning, she attempted to kill her son by stabbing him in the neck and trying to drown him. The son managed to escape and tried to call 911, but the defendant took his phone and told the dispatcher everything was fine. The son eventually called the police, who found him injured and the defendant attempting to harm herself.The defendant was indicted on multiple charges, including assault and battery by means of a dangerous weapon and attempted murder. After a bench trial, the Superior Court judge found her not guilty by reason of mental illness for the assault and attempted murder charges but guilty of reckless endangerment and witness intimidation. She was sentenced to five years of probation with conditions, including no unsupervised contact with her children and GPS monitoring for two years. The defendant appealed, and the Supreme Judicial Court granted direct appellate review.The Supreme Judicial Court upheld the convictions, finding sufficient evidence that the defendant was criminally responsible for her actions after the attack. The court determined that the defendant understood the criminality of preventing her son from calling 911 and could conform her conduct to the law. The court also found the indictment for reckless endangerment was not impermissibly ambiguous and that the GPS monitoring condition of probation was reasonable. The court affirmed the convictions and the probation condition. View "Commonwealth v. Rezac" on Justia Law

The case involves the defendant, Maryann Russo, who was charged with animal cruelty under G. L. c. 272, § 77, for her treatment of her terminally ill fourteen-year-old cocker spaniel, Tipper. Russo brought Tipper to a veterinarian who recommended euthanasia due to Tipper's severe health issues, including a large necrotic mass, bed sores, and open wounds. Russo declined euthanasia, falsely stating she would take Tipper to another veterinarian, and instead took him home. The Animal Rescue League (ARL) later removed Tipper from Russo's care after the veterinarian reported her suspicions. Tipper was found in poor condition and was subsequently euthanized.In the Quincy Division of the District Court, a criminal complaint was issued against Russo in February 2021. Russo filed a motion to dismiss the complaint, arguing it lacked probable cause. The District Court judge granted the motion, concluding that the statute did not impose an affirmative obligation to euthanize an animal. The Commonwealth appealed, and the Appeals Court affirmed the dismissal, reasoning that the statute did not criminalize the failure to euthanize an animal. The Supreme Judicial Court granted further appellate review.The Supreme Judicial Court affirmed the dismissal, holding that the Commonwealth failed to establish probable cause that Russo acted with the requisite criminal intent. The court concluded that the statute required proof that Russo knowingly and willfully authorized or permitted Tipper to be subjected to unnecessary suffering. The court found that Russo's actions, including seeking medical care and attempting to make Tipper comfortable, did not indicate an intent to cause unnecessary suffering. The court emphasized that speculation alone was insufficient to establish probable cause. View "Commonwealth v. Russo" on Justia Law

The defendant was convicted of first-degree murder for the stabbing death of Jordan Baskin. After his conviction, the defendant filed a motion for a new trial, claiming his trial counsel provided ineffective assistance during a police interview where incriminating evidence was obtained. The defendant argued that his trial counsel failed to provide effective representation and had a conflict of interest because filing a motion to suppress the evidence would have been against her own interests.The Superior Court judge allowed the motion for a new trial, finding that the trial counsel had an actual conflict of interest and that the defendant did not waive this conflict knowingly and intelligently. The judge concluded that the conflict alone warranted a new trial without needing to show additional prejudice.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the lower court's decision. The court found that the trial counsel's personal interests materially interfered with her independent professional judgment, creating an actual conflict of interest. This conflict arose because the trial counsel's performance during the police interview was in question, and she could not provide detached advice or pursue a motion to suppress the evidence obtained during the interview zealously. The court also determined that the defendant did not validly waive this conflict, as the colloquies before trial did not address the specific conflict related to the adequacy of counsel's performance at the police interview. Therefore, the court affirmed the order for a new trial. View "Commonwealth v. Brown" on Justia Law

In November 2004, a sixteen-year-old juvenile stalked and robbed a victim at gunpoint, repeatedly raped her in her home, and then bound, gagged, and robbed her roommate when she arrived. He was sentenced to state prison for aggravated rape and other offenses, with a period of parole ineligibility compliant with constitutional requirements. After serving his prison term, he was placed on probation for the remaining nonhomicide offenses.In March 2007, the juvenile was adjudicated as a youthful offender and sentenced to sixteen to twenty years in state prison for aggravated rape, with additional concurrent and consecutive sentences for other offenses. In 2021, following a court decision, his sentence was restructured to comply with constitutional requirements, reducing his parole ineligibility to fifteen years. He was released from prison in January 2022 and began a five-year probation term. In August 2022, he was arrested for new offenses, leading to a probation violation notice and detention.The Supreme Judicial Court of Massachusetts reviewed the case. The court held that the restructured sentence, including the probation term, did not violate constitutional protections against cruel or unusual punishment. The court emphasized that the probation term provided the juvenile with an opportunity for rehabilitation and reintegration into the community. The court also noted that any potential further incarceration resulting from a probation violation would be subject to constitutional constraints, ensuring that the juvenile would not be treated more harshly than a juvenile convicted of murder for parole eligibility purposes. The court affirmed the order denying the juvenile's motion for relief from unlawful restraint. View "Commonwealth v. Sajid S." on Justia Law

The case revolves around the defendant, Mark O'Brien, who was convicted of first-degree murder for the killing of Robert McKenna. The murder occurred during a robbery scheme where O'Brien and his two co-venturers entered McKenna's home to steal marijuana, a firearm collection, and other valuables. The robbery turned violent when they found McKenna awake, leading to a struggle where they struck McKenna repeatedly in the head with a metal frying pan, causing his death. No DNA or other forensic evidence placed O'Brien at the scene, leading to his defense that he was not the third co-venturer.The Superior Court Department found and returned indictments against O'Brien on November 24, 2015. The cases were tried before Jeffrey A. Locke, J., and a motion for a new trial, filed on August 27, 2021, was heard by Mark A. Hallal, J. O'Brien was convicted of murder in the first degree and twelve other charges. He appealed his conviction and also filed a motion for a new trial, arguing that he received ineffective assistance of counsel because his trial counsel withdrew a request for an involuntary manslaughter jury instruction.The Supreme Judicial Court of Massachusetts reviewed the case and found no error in the lower court's proceedings. The court held that the defendant's counsel's decision to withdraw the request for an involuntary manslaughter instruction was not manifestly unreasonable given the evidence. The court also found no prosecutorial misconduct in the handling of the informant's testimony or the closing argument. However, the court vacated the defendant's convictions of unlawful possession of a firearm and remanded those charges for a new trial, in light of a recent Supreme Court decision requiring the prosecution to prove lack of licensure. The court affirmed the defendant's other convictions and the order denying his motion for a new trial. View "Commonwealth v. O'Brien" on Justia Law

In June 2015, Jose Lora, a member of the Kilby Street Posse (KSP), a Worcester-based gang, shot and killed David Luyando, an innocent bystander, at a cemetery. Lora was targeting Kevin Parker, a member of a rival gang, the Providence Street Posse (PSP), who had shot Lora six days earlier. After the shooting, Lora disposed of the murder weapon, cleaned his car, and fled to the Dominican Republic. He was later returned to the Commonwealth and convicted of first-degree murder on a theory of deliberate premeditation.The Superior Court Department found and returned an indictment against Lora on May 20, 2016. After a jury trial, Lora was convicted of first-degree murder. He filed a motion for a new trial on September 10, 2021, which was considered and denied by the same judge who presided over his trial.In his appeal, Lora argued that the trial judge erred by not instructing the jury to consider Parker's known history of violence in assessing whether Lora had a reasonable apprehension of Parker at the time of the killing. He also claimed that the judge abused his discretion in denying his motion for a new trial because the prosecutor delayed disclosure of material evidence, and because he received ineffective assistance of counsel.The Supreme Judicial Court of Massachusetts affirmed the conviction and the denial of the motion for a new trial. The court found no error in the trial judge's actions and no reason to exercise its extraordinary authority to order a new trial or to reduce the verdict of murder in the first degree to a lesser degree of guilt. The court concluded that the evidence presented at trial supported the jury's finding of deliberate premeditation and rejected Lora's claims of error and ineffective assistance of counsel. View "Commonwealth v. Lora" on Justia Law

The case involves a defendant, Nelson Barros, who was charged with assault and battery on a household member. Barros, a noncitizen, chose to represent himself during his arraignment and plea hearing. He signed a form acknowledging he had waived his right to counsel. The judge did not conduct any further inquiry to determine whether Barros' waiver of counsel was made knowingly and intelligently. Barros later admitted to sufficient facts to warrant a guilty verdict and was placed on probation for one year. After completing his probation, the charge was dismissed. However, upon returning to the U.S. from a trip to Portugal, Barros was detained by Immigration and Customs Enforcement officers due to his admission of guilt in the assault case.The lower courts denied Barros' motions to withdraw his plea. The motion judge found that Barros' waiver of the right to counsel was knowing and voluntary. Barros appealed, and the Supreme Judicial Court granted his application for direct appellate review.The Supreme Judicial Court of Massachusetts held that a defendant's waiver of the right to counsel must be made knowingly and intelligently, regardless of whether the defendant is at arraignment or a plea hearing. The court confirmed that a trial court judge has the responsibility of ascertaining whether the waiver is made knowingly and intelligently. The court also recognized that for a noncitizen defendant, the disadvantages of self-representation include forgoing counsel's advice about the immigration consequences of a disposition. However, the court affirmed the lower court's decision on alternate grounds, concluding that Barros' waiver of counsel was invalid, but he failed to establish a substantial risk of a miscarriage of justice to prevail on appeal. View "Commonwealth v. Barros" on Justia Law

The case revolves around a defendant, Nelson Barros, who was charged with one count of assault and battery on a household member. Barros, a noncitizen, chose to represent himself during his arraignment and plea hearing. He signed a form acknowledging he had waived his right to counsel. The judge informed him of his right to counsel and confirmed that Barros wished to represent himself. However, the judge did not conduct any further inquiry to determine whether Barros' waiver of counsel was made knowingly and intelligently. Barros admitted to sufficient facts to warrant finding him guilty and was placed on one year of probation. Later, Barros was detained by Immigration and Customs Enforcement officers due to his admission to sufficient facts to find him guilty of assault and battery on a household member.The lower courts denied Barros' motions to withdraw his plea. The motion judge, who was not the plea judge, found that Barros' waiver of the right to counsel was knowing and voluntary. Barros appealed, and the Supreme Judicial Court granted his application for direct appellate review.The Supreme Judicial Court of Massachusetts affirmed the lower court's decision but on alternate grounds. The court held that Barros' waiver of counsel was invalid, in violation of his right to counsel under art. 12 of the Massachusetts Declaration of Rights. The judge did not conduct an adequate inquiry to determine whether Barros' waiver of counsel was made knowingly and intelligently. However, Barros did not challenge this waiver of counsel in his first motion to withdraw his admission to sufficient facts. Therefore, he must establish a substantial risk of a miscarriage of justice to prevail on appeal. The court concluded that Barros did not raise a serious doubt that the result of the proceeding might have been different had his waiver of counsel been adequately informed. View "Commonwealth v. Barros" on Justia Law

The case involves Brandyn Lepage, who was convicted of first-degree murder on the theory of felony-murder. Lepage shot and killed Aja Pascual in her car on September 29, 2012. The police obtained call logs from the victim's phone, which showed that Lepage had called the victim shortly before her death. The police also obtained Lepage's cell phone records, including call detail records, historical cell site location information (CSLI), and ping data, without a warrant. Lepage appealed his conviction and the denial of his motion for a new trial, arguing that the police illegally obtained his cell phone records.The Superior Court Department had denied Lepage's pretrial motions to suppress the cell phone records. The court found that the police did not illegally obtain Lepage's call detail records and did not use the CSLI or ping data in the manner Lepage alleged. Lepage's motion for a new trial was also denied by the same judge who had previously denied his motions to suppress.The Supreme Judicial Court affirmed Lepage's conviction of murder in the first degree and the denial of his motion for a new trial. The court concluded that Lepage did not have a reasonable expectation of privacy in his call detail records, and therefore the police did not need a warrant to obtain this information. The court also found that the police did not use Lepage's CSLI or ping data to secure evidence against him. Therefore, the court concluded that there was no violation of Lepage's constitutional rights. However, the court vacated Lepage's conviction of unlawful possession of a firearm and remanded for a new trial on that indictment. View "Commonwealth v. Lepage" on Justia Law