Justia Massachusetts Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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The Supreme Judicial Court vacated the order of the superior court denying Appellant's motion for refund of parole supervision fees she paid while on parole, holding that Appellant was entitled to return of the parole fees she paid.Appellant's convictions were vacated and the charges against her dismissed with prejudice due to the misconduct of Annie Dookhan, a chemist at the William A. Hinton State Laboratory Institute. Appellant subsequently filed a motion in her criminal case seeking a refund of the parole supervision fees that she had paid as a result of her invalidated convictions and a waiver of the remaining balance she owed. The superior court denied the motion, concluding that a motion filed in the criminal case was not the correct way to seek a refund of parole fees. The Supreme Judicial Court vacated the judgment, holding (1) Appellant was entitled to a return of her previously paid parole fees; and (2) Appellant correctly filed her motion for a refund in the same criminal case in which her convictions had been invalidated. View "Commonwealth v. Nieves" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court affirmed the judgment of the 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 his discretion in denying relief.Petitioner was indicted on several counts of rape and one count of strangulation or suffocation. Petitioner was committed for observation to Bridgewater State Hospital for a determination whether he was competent to stand trial. Petitioner was found incompetent to stand trial and committed to the hospital pursuant to Mass. Gen. Laws ch. 123, 16. Petitioner, who remains in the hospital, filed a Mass. Gen. Laws ch. 211, 3 petition claiming, among other things, that his constitutional rights had been violated. The single justice denied the petition without a hearing. The Supreme Judicial Court affirmed, holding that Petitioner had an adequate alternative remedy and that his claims did not present a situation warranting extraordinary superintendence relief pursuant to Mass. Gen. Laws ch. 211, 3. View "Ardaneh v. Commonwealth" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the county court denying, without a hearing, Defendant's petition under Mass. Gen. Laws ch. 211, 3 for relief from home confinement as a condition of his bail, holding that the single justice properly denied relief.Defendant was charged with open and gross lewdness, subsequent offense. At Defendant's arraignment, a district court judge set bail and, as a condition of release, ordered that Defendant be subject to GPS monitoring and confined to the interior of his home. Defendant was released subject to these conditions. Defendant later filed his Mass. Gen. Laws ch. 211, 3 petition challenging the order of home confinement. The single justice denied relief. The Supreme Judicial Court affirmed, holding the bail judge was within his discretion to order Defendant to remain inside the house. View "Falcone v. Commonwealth" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court affirmed Defendant's convictions of murder in the first degree by deliberate premeditation and assault with intent to murder, holding that no error occurred in the proceedings below.Specifically, the Supreme Judicial Court held (1) the motion judge did not err in denying Defendant's motion to suppress because (a) although Defendant unambiguously invoked his right to counsel, he voluntarily reinitiated contact with detectives, and (b) Defendant's waiver of his Miranda rights was intelligent, knowing, and voluntary; (2) factually inconsistent verdicts were no grounds to set aside Defendant's convictions of murder in the first degree and assault with the intent to murder because ample evidence supported both convictions; and (3) the verdict of murder in the first degree was consonant with justice, and there was no basis to set aside the verdict or order a new trial pursuant to the Court's extraordinary power under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Miller" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree and unlawful possession of a firearm, holding that no error occurred during the proceedings below.Specifically, the Supreme Judicial Court held (1) one of the Commonwealth's key witnesses did not provide improper lay testimony on the ultimate issue of Defendant's guilt; (2) Defendant's argument that a substantial likelihood of a miscarriage of justice occurred because the judge did not provide a self-defense instruction sua sponte was without merit; (3) trial counsel did not provide ineffective assistance for strategically deciding against requesting a self-defense instruction; and (4) there was no basis to set aside the verdict of murder in the first degree or to order a new trial pursuant to the Court's extraordinary power under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Waller" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on the theory of deliberate premeditation, holding that there was no prejudicial error in the proceedings below.After Defendant was convicted of murder, the Supreme Judicial Court reversed the conviction due to an error in the jury instructions. Following a retrial, Defendant was again convicted of murder. Defendant filed a motion for a new trial, which the trial court denied. The Supreme Judicial Court affirmed, holding (1) the trial judge's decision to allow a witness to avoid testifying at the second trial by invoking the privilege against self-incrimination and in admitting the witness's voir dire testimony, in lieu of live testimony at the second trial, did not create a substantial likelihood of a miscarriage of justice; (2) the trial court did not err in denying Defendant's motion for a new trial on the ground that he suffered from a mental disease or defect at the time of the shooting; (3) this Court again declines to extend its holding in Diatchenko v. District Attorney for the Suffolk District, 466 Mass. 655 (2013), to individuals over the age of eighteen; and (4) Defendant's arguments made pursuant to Commonwealth v. Moffett, 383 Mass. 201, 208-209 (1981) were unavailing. View "Commonwealth v. Johnson" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree but dismissed Defendant's convictions of possession of ammunition, holding that those convictions were duplicative of the convictions of possession of a loaded firearm.Defendant was convicted of murder in the first degree and on twenty-four other indictments that included various firearms charges and other charges related to the injuries Defendant inflicted on victims when he fired shots at a New Year's Eve house party. The Supreme Judicial Court affirmed, holding (1) there was not a substantial likelihood of a miscarriage of injustice even though the verdict slip indicated that the jury found Defendant guilty of both murder in the first degree and murder in the second degree; (2) two convictions of possession of ammunition must be dismissed because they were lesser included offenses of Defendant's convictions of possession of a loaded firearm; and (3) this Court declines to exercise its extraordinary power under Mass. Gen. Laws ch. 278, 33E to order a new trial or to reduce the degree of guilt. View "Commonwealth v. Phuon" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court affirmed the judgment of the single justice of the court denying Petitioner's petition for extraordinary relief pursuant to Mass. Gen. Laws ch. 211, 3, holding that the extraordinary remedy of general superintendence was not required in this matter.In his petition, Petitioner claimed that Respondents had engaged in a conspiracy to deprive him of due process in his criminal matter and in his efforts to apply for criminal complaints. The single justice denied the petition without a hearing. The Supreme Judicial Court affirmed, holding that Petitioner had adequate alternative avenues to seek the relief he requested in connection with the criminal case against him. View "Roberts v. Hingham Division of the District Court Department" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court affirmed Defendant's conviction of two counts of possession of child pornography, in violation of Mass. Gen. Laws ch. 272, 29C, holding that the information in the search warrant was sufficient for a magistrate to have found probable cause.Seven months after Defendant's alleged illegal activity, a police trooper obtained a warrant authorizing a search of all computer systems and digital storage devices located within Defendant's residence for evidence of child pornography. During the execution of a search warrant Defendant's laptop computer and flash drive were seized. On appeal from his conviction, Defendant argued that the passage of seven months between the alleged upload of child pornography and the application for a search warrant rendered the warrant stale so that it lacked probable cause. The Supreme Judicial Court affirmed, holding that the motion judge did not err in finding that the information in the warrant affidavit was not stale when the warrant was filed. View "Commonwealth v. Guastucci" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court affirmed Defendant's convictions of carrying a firearm without a license and of possessing a loaded firearm, holding that no prejudicial error occurred in the proceedings below.Specifically, the Supreme Judicial Court held (1) the motion judge did to err in denying Defendant's motion to suppress the firearm; (2) there was sufficient evidence to support the conviction of possession of a loaded firearm; (3) the trial court's failure to instruct the jury that Defendant had to know that the firearm was loaded did not create a substantial risk of a miscarriage of justice; and (4) there was no error in the prosecutor's closing arguments. View "Commonwealth v. Silvelo" on Justia Law

Posted in: Criminal Law