Justia Massachusetts Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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The Supreme Judicial Court affirmed Defendant's conviction of unlawful distribution of heroin as a subsequent offender and unlawful possession of heroin with intent to distribute as a subsequent offender, holding that the superior court did not err by denying Defendant's motion to suppress and that there was no other error.In his suppression motion, Defendant sought to suppress evidence found during a warrantless search of a motor vehicle. The superior court denied the motion to suppress. The Supreme Judicial Court affirmed the denial of the suppression motion and Defendant's convictions, holding (1) the police had probable cause to search the vehicle, and there was no error in the denial of the motion to suppress; (2) the trial judge erred in allowing the admission of an in-court identification made by a police officer, but the error did not prejudice Defendant; and (3) there was no substantial risk of a miscarriage of justice as to the jury instructions on possession and distribution of narcotics. View "Commonwealth v. Ortiz" on Justia Law

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In this appeal from various orders regarding Defendant's pretrial detention status the Supreme Judicial Court vacated the decision of the single justice concluding that no due process violation occurred regarding one case and ruled that the other case was moot, holding that remand was required for a determination as to whether Defendant's continued pretrial confinement violates due process.Defendant had been held in pretrial detention for more than eighteen months on charges arising out of the Chelsea Division and the Lynn Division of the District Court Department. At the time of this opinion, Defendant had been held for over a year beyond his initial trial dates. Defendant was eventually acquitted of the charges in the Chelsea case. In the Lynn case, Defendant's trial was delayed due to the COVID-19 pandemic. At issue was whether the prolonged detention violated Defendant's due process rights. The Supreme Judicial Court held (1) in analyzing whether a defendant's pretrial detention violates due process this opinion contains a procedural framework; (2) because Defendant was acquitted in the Chelsea case, that case was moot; and (3) as to the Lynn case, the matter must be remanded for further proceedings. View "Mushwaalakbar v. Commonwealth" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the sentencing judge denying Defendant's motion to dismiss revocation proceedings and the finding that Defendant violated conditions of his probation, holding that there was no error.Defendant was convicted of indecent assault and battery on a child and sentenced to two separate periods of incarceration, the latter of which was to be suspended in favor of probation. Upon release from his confinement, Defendant began serving the probation phase of his sentence. One year later, Defendant was found to have violated the conditions of his probation, and his probation was revoked. On appeal, Defendant argued that his probationary term should have terminated prior to the occurrence of the violations. The Supreme Judicial Court affirmed, holding that it was not fundamentally unfair to delay the commencement of Defendant's probationary term until he was released from the treatment center into the community. View "Commonwealth v. Medina" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court vacated the judgment of the superior court affirming the decision of the Sex Offender Registry Board denying Doe's motion to vacate her final classification as a level three sex offender, holding that Doe's premature classification violated due process.In 2012, years before her potential release date from prison, Doe was classified as a level three sex offender. She did not challenge the classification at the time. In 2019, Doe moved to vacate the final classification on the grounds that it was premature. The Board denied the motion. The Supreme Judicial Court affirmed, holding that the classification violated due process because it served little to no purpose, posed an unnecessary risk of harm and error and was not justified by the Board's limited interest in finality or administrative efficiency. View "Doe v. Sex Offender Registry Board" on Justia Law

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The Supreme Judicial Court vacated the decision of the superior court judge allowing Defendant's motion to suppress, holding that Defendant enjoyed no reasonable expectation of privacy in the text messages sent by him that were stored on a cellular telephone belonging to, and possessed by, another person.Defendant and six codefendants were indicted on charges of trafficking in cocaine, conspiracy to violate drug laws, and conspiracy to commit money laundering. The charges stemmed from an investigation originating, in part, from evidence acquired during a search of a codefendant's cell phone. The owner of the telephone filed a motion to suppress evidence obtained as a result of the search of his phone, including the contents of text messages sent by Defendant. Defendant moved to join the motion. The Commonwealth opposed the motion, arguing that Defendant lacked standing to challenge the search. The judge ruled that Defendant had standing and allowed him to join the motion. The Supreme Judicial Court reversed, holding that Defendant could not challenge the reasonableness of the search because he lacked a reasonable expectation of privacy in the sent text messages. View "Commonwealth v. Delgado-Rivera" on Justia Law

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The Supreme Judicial Court affirmed in part the judgment of a single justice of the court denying Petitioner's petition filed pursuant to Mass. Gen. Laws ch. 211, 3 seeking bail review but remanded the case for the judge to make required findings pursuant to Brangan v. Commonwealth, 477 Mass. 691 (2017), holding that further proceedings were necessary.Petitioner was indicted on numerous charges. A superior court judge initially set cash bail at $100,000. Two years later, Petitioner, who was unable to pay the cash bail, sought review of the bail determination. A judge reduced the cash bail to $30,000 but did so without any findings or explanation. Petitioner later filed this petition seeking bail review, arguing that the cash bail amount of $30,000 was excessive. The single justice denied the petition without a hearing. The Supreme Judicial Court remanded the case with directions for the judge who made the bail reduction decision to make the required findings for that decision pursuant to Brangan, holding that the judge should have made findings for that decision. View "Boisvert v. Commonwealth" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court affirmed the judgment of a single justice of the court denying Petitioner's petition filed pursuant to Mass. Gen. Laws ch. 211, 3, holding that the single justice did not err or abuse his discretion in denying relief.Petitioner, an inmate, filed a complaint seeking declaratory and injunctive relief in connection with two Massachusetts Department of Correction (DOC) standard operating procedures (SOPs) implemented earlier that year. Petitioner also sought a temporary restraining order and a preliminary injunction to prevent DOC from enforcing the SOPs during the pendency of this case. The superior court judge denied Petitioner's injunction request as moot and ordered that judgment enter declaring that implementation of the first SOP violates 103 Code Mass. Regs. 481. Petitioner then filed this petition seeking review of the superior court's judgment and orders. The single justice denied the petition. The Supreme Judicial Court affirmed, holding that Petitioner failed to show that review of the trial court decision could not adequately be obtained on appeal or by other available means. View "Wright v. Department of Correction" on Justia Law

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The Supreme Judicial Court affirmed the judgment of a single justice of the court denying Petitioner's petition pursuant to Mass. Gen. Laws ch. 211, 3, holding that the single justice did not err or abuse her discretion in denying relief.Petitioner was charged in six separate complaints with several offenses, including assault and battery on a family or household member. The Commonwealth moved to join the cases, and a district court judge allowed the motion. After Petitioner's motion for reconsideration was denied he filed this petition, arguing that not reviewing the joinder decision now could lead to irreversible consequences. A single justice denied the petition. The Supreme Judicial Court affirmed, holding that Petitioner failed to show that review of the trial court decision could not adequately be obtained on appeal or by other available means. View "Morris v. Commonwealth" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court affirmed Defendant's convictions for two counts of murder in the first degree and the denial of his motion for a new trial, holding that Defendant was not deprived of his constitutional right to the effective assistance of counsel.On appeal, Defendant argued, among other things, that it was manifestly unreasonable for his trial counsel to forgo mental health defenses in favor of a third-party culprit defense. The Supreme Judicial Court disagreed, holding (1) trial counsel was not ineffective for urging one defense over the other, and Defendant was not prejudiced by his trial counsel's performance; and (2) there was no basis upon which to exercise the Court's extraordinary authority to order a new trial or to reduce the verdicts pursuant to Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Velez" on Justia Law

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The Supreme Judicial Court dismissed as moot Plaintiffs' appeal arguing that the Department of Correction (DOC) illegally kept them in custody after a final decision on their petitions for medical parole had been made by the Commissioner of Correction but answered two questions reported by the single justice.Plaintiffs were two prisoners recently released under the medical parole statute. Before their actual release from incarceration, Plaintiffs sought relief from a single justice of the court. The single justice denied Plaintiffs' request for relief and separately reported two questions to the Supreme Judicial Court regarding the requirements of finding a replacement for a prisoner who is granted medical parole and the timing of a prisoner's release after medical parole is granted. The Supreme Judicial Court dismissed Plaintiffs' appeal as moot and answered (1) after medical parole is granted the DOC must develop comprehensive plans including a proposed course and site for treatment; and (2) once a favorable decision by the Commissioner allows release on medical parole, the DOC must be proactive in working to release the prisoner expeditiously. View "Malloy v. Department of Correction" on Justia Law