Justia Massachusetts Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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In the case of Commonwealth v. Rashad Shepherd, the Supreme Judicial Court of Massachusetts affirmed the defendant’s conviction of murder in the first degree on the theory of felony-murder, with attempted unarmed robbery as the predicate felony. The case centered around a failed robbery attempt that ended in the shooting and death of the intended victim. The defendant, along with two co-conspirators, hatched a plan to rob the victim, who was known to sell marijuana from his apartment. However, when the plan was put into motion, the victim resisted, and in the ensuing altercation, was shot and killed. The prosecution's theory was that the defendant was the shooter.In his appeal, the defendant argued that the court’s decision in a prior case, Commonwealth v. Brown, which abolished felony-murder as an independent theory of liability for murder in the first and second degrees, should be applied to his case retroactively. He maintained that not doing so violated equal protection principles as more Black individuals were serving life sentences without parole for felony-murder than white individuals. However, the court rejected this argument, noting that the decision in Brown was applied to all equally, regardless of race or ethnicity.The defendant also claimed errors in jury instructions and conduct by the trial judge, but the court determined that there was no reversible error. Lastly, the defendant argued that he received ineffective assistance of counsel, but the court found that the decisions by the defense were not manifestly unreasonable. View "Commonwealth v. Shepherd" on Justia Law

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In the case before the Supreme Judicial Court of Massachusetts, the defendant, William J. Camuti, was convicted of murder in the first degree for poisoning his friend and business associate, Stephen Rakes, with potassium cyanide. Several years after his conviction, Camuti filed a postconviction motion for forensic testing of the shirt that Rakes was wearing when his body was found, claiming that DNA testing of the shirt could potentially provide evidence that could exonerate him. However, a Superior Court judge denied the motion, finding that Camuti had failed to meet his burden under G. L. c. 278A, § 7 (b), to demonstrate that a reasonably effective defense attorney would have sought to test Rakes' shirt for DNA.On appeal, the Supreme Judicial Court affirmed the lower court's decision. The court reasoned that the absence of trace evidence, including DNA evidence, was a central part of Camuti's defense strategy at trial. His counsel had repeatedly emphasized the lack of physical evidence linking Camuti to the crime scene, and the introduction of DNA evidence from Rakes' shirt could have undermined this defense. The court further noted that even if DNA testing had revealed the presence of a third party's DNA on the shirt, this would have had minimal exculpatory value given the circumstances of the case. Given these considerations, the court concluded that a reasonably effective attorney would not have sought DNA testing of Rakes' shirt. Therefore, Camuti had not met his burden under G. L. c. 278A, § 7 (b), and the denial of his postconviction motion for forensic testing was affirmed. View "Commonwealth v. Camuti" on Justia Law

Posted in: Criminal Law
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The case involves the Commonwealth's appeal against the trial judge's denial of its motion to admit expert testimony on Frequent Location History (FLH) data retrieved from the defendant's cell phone in a murder case. The Commonwealth argued that the FLH data would corroborate its witness's testimony, placing the defendant at the crime scene. The trial judge denied the motion, stating that the Commonwealth had not met its burden of showing that FLH data had been generally accepted as reliable by the scientific community. The judge also found that the Commonwealth had failed to provide evidence that FLH data has been subjected to peer review or publication, has an unacceptably high known or potential rate of error, and is governed by recognized standards. The Supreme Judicial Court for the county of Suffolk agreed with the trial judge's decision, concluding that the Commonwealth had not shown that FLH data is reliable. Therefore, the court affirmed the trial judge's denial of the Commonwealth's motion to admit the FLH data. View "Commonwealth v. Arrington" on Justia Law

Posted in: Criminal Law
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In 1995, the bodies of a woman and her daughter were found in separate locations in Massachusetts and Connecticut. More than two decades later, the woman's husband was convicted for her murder. On appeal, he asserted that the evidence was insufficient to establish his identity and deliberate premeditation, and challenged the admissibility of his daughter's murder evidence, the testimony of two latent print examiners, and the limitation on introducing a potential third-party culprit.The Supreme Judicial Court of Massachusetts affirmed the conviction. The court found no reversible error in the trial court's decisions and determined that the evidence was sufficient for the jury to find that the husband was the perpetrator and committed the crime with deliberate premeditation. The court also ruled that the evidence of the daughter's murder was admissible to establish the identity of the perpetrator of the mother's murder. The court also found no issues with the testimony of the latent print examiners and did not find any unfair limitations on the defendant's ability to present evidence of a potential third-party culprit. Furthermore, the court ruled that the defendant's rights to confront witnesses were not violated by the testimony of the latent print examiners. Lastly, the court deemed that the defendant's argument on the degree of certainty expressed by the latent print examiners was unpreserved, and the error did not create a substantial likelihood of a miscarriage of justice. View "Commonwealth v. Honsch" on Justia Law

Posted in: Criminal Law
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The case concerns the constitutional rights of a criminal defendant, A.Z., who was involuntarily hospitalized for a competency determination under Massachusetts law, G. L. c. 123, § 15 (b). The Supreme Judicial Court of Massachusetts held that the involuntary commitment of a criminal defendant for a competency determination infringes upon a defendant's fundamental right to liberty and thus must satisfy strict scrutiny under the Massachusetts Declaration of Rights and the United States Constitution. To pass strict scrutiny, the involuntary commitment must be the least restrictive means available to vindicate the governmental interest at stake. Therefore, it is unconstitutional for a court to hospitalize a pretrial defendant for a clinical evaluation and observation of competency, absent a finding by the judge, by clear and convincing evidence, that hospitalization is the least restrictive means available to adequately determine a criminal defendant's competency to stand trial. The judge in this case did not make such findings, so the court concluded that the defendant's constitutional rights were violated. View "Commonwealth v. A.Z." on Justia Law

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In 1982, William F. McDermott was convicted of first-degree murder. On direct review, the Supreme Judicial Court of Massachusetts found that the trial judge had erred in failing to instruct the jury that evidence of intoxication could be considered in determining whether McDermott acted with extreme atrocity or cruelty to support a verdict of first-degree murder. Instead of ordering a new trial, the court reduced the verdict to murder in the second degree.In 2020, McDermott filed a motion for a new trial, claiming prosecutorial misconduct, improper jury instruction, and arguing that his sentence of life with the possibility of parole was unconstitutional. The Supreme Judicial Court found that while the prosecutor had engaged in misconduct, the errors did not create a substantial risk of a miscarriage of justice. The court also held that McDermott's challenges to the jury instructions were estopped by prior postconviction rulings, and that his sentence was not unconstitutional.The court affirmed the denial of McDermott's motion for a new trial. View "Commonwealth v. McDermott" on Justia Law

Posted in: Criminal Law
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In this case, six plaintiffs -- two criminal defense organizations, two defense attorneys, and two former criminal defendants -- filed a petition against the District Attorney's Office for the Hampden District in Massachusetts. The plaintiffs alleged multiple failures by the District Attorney's Office, primarily stemming from its handling of evidence of misconduct within the Springfield Police Department (the department). The U.S. Department of Justice had previously conducted an investigation and found that officers in the department, particularly those within the narcotics bureau, routinely falsified police reports and engaged in a pattern of excessive force.The Supreme Judicial Court of Massachusetts found that the District Attorney's Office, through certain discovery policies, committed a breach of both the duty to disclose evidence that tends to exculpate defendants and the duty to investigate or inquire about such evidence. Specifically, the court identified three problematic practices: 1) disclosing adverse credibility findings made about the department's officers only on a discretionary basis; 2) withholding instances of officer misconduct from disclosure where a specific bad act cannot be clearly attributed to a particular officer; and 3) failing to gain access to all documents known to have been reviewed by the Department of Justice (DOJ).To rectify these breaches, the court ordered the District Attorney's Office to obtain access to all categories of documents known to have been reviewed by the DOJ and disclose them to the plaintiffs. From there, case-by-case adjudication can begin to address the claims of individual defendants affected by the department's misconduct. In issuing this order, the court emphasized the importance of a prosecutor's dual duties -- to disclose and to investigate -- in upholding the integrity of the criminal justice system. View "Graham v. District Attorney for the Hampden District" on Justia Law

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In a case before the Supreme Judicial Court of Massachusetts, the defendant, Denzel McFarlane, convicted of unlawful possession of a firearm and other related charges, appealed for a new trial. He based his appeal on the fact that a police officer who had arrested and testified against him was found civilly liable for false arrest and false imprisonment in an unrelated lawsuit. McFarlane argued that the existence of the civil lawsuit against the officer was exculpatory information that the prosecution should have disclosed to the defense but failed to do so.The primary legal issue was whether the existence of a pending civil lawsuit against a police officer must be disclosed by a prosecutor as exculpatory evidence. The court held that the existence of a pending civil lawsuit against a police officer does not need to be disclosed by a prosecutor as exculpatory evidence. The court reasoned that until a finding of liability has been made, a pending civil lawsuit constitutes an unsubstantiated allegation of police misconduct that does not tend to negate the guilt of the defendant. Therefore, the court affirmed the denial of McFarlane's motion for a new trial.In addition, the court established that while a prosecutor has no duty to inquire into pending civil lawsuits against a prosecution team member, the duty of inquiry does require that prosecutors inquire about the existence of any findings of civil liability related to the performance of a police officer's duties. In other words, if a police officer has been found liable in a civil lawsuit, the prosecution has a duty to discover that information and potentially disclose it to the defense. View "Commonwealth v. Mcfarlane" on Justia Law

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The case involves the Commonwealth's appeal of a judgment by a single justice of the Supreme Judicial Court of Massachusetts, which upheld a lower court judge's decision to disqualify a prosecutor, Matthew Green, from a murder case. The defendant, Blake Scanlon, had been indicted on murder charges and was also later charged with soliciting to commit witness intimidation and murder. One of the solicitation targets was Green, the prosecutor for the initial murder indictment. The basis for Green's disqualification was not because he was a victim in the solicitation case, but because he made himself a potential witness at trial. This was due to his interactions with a jailhouse informant, with whom Scanlon was incarcerated and who claimed Scanlon solicited him for a murder-for-hire plot. In exchange for the informant's cooperation, Green advocated for lighter sentences and bail conditions for him in separate legal proceedings. The defendant argued that these actions made Green a potential witness, either to confirm or dispute the informant's claims, or to question the informant's credibility due to bias in favor of the Commonwealth. The lower court judge agreed and disqualified Green from the case. The Commonwealth appealed, arguing that Green's disqualification was an error, as he was only a potential witness, and that other means could be used to present the necessary information at trial. The Commonwealth also argued that the disqualification raised separation of powers concerns by interfering in the executive branch's discretion to choose a prosecutor. The Supreme Judicial Court disagreed, affirming the lower court judge's decision. It found that the level of Green's involvement with the informant's legal proceedings was extensive, making him more than just a potential witness, and that the judge's decision did not constitute an intolerable interference in the executive branch. View "Commonwealth v. Scanlon" on Justia Law

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In this case, a Superior Court judge in Massachusetts sought guidance from the Supreme Judicial Court on three questions involving the pretrial confinement of a juvenile charged with murder. The juvenile, who was sixteen years old when he was charged with second-degree murder, was initially held without bail at a Department of Youth Services (DYS) facility due to a "courtesy" arrangement with the county sheriff. As the juvenile neared his eighteenth birthday, he was informed that he would be moved to an adult facility. In response, a Superior Court judge released him on personal recognizance on the murder charge and set bail on a related non-murder charge, ordering that he stay at the DYS facility.The Supreme Judicial Court of Massachusetts was asked to determine: 1) whether a Superior Court judge can commit a person under age eighteen charged with murder to DYS's care as a pre-trial detainee; 2) if not, can a Superior Court judge set bail on a charge related to, but other than murder, so that the person under eighteen is not held on bail on the murder charge and is committed to DYS's care; and 3) if the answers to questions 1 and 2 are "No," is the last paragraph of G. L. c. 119, § 68 (which mandates that juveniles charged with murder be committed to the custody of the sheriff) unconstitutional?The Supreme Judicial Court declined to answer the third question due to mootness, as the defendant had since turned eighteen and pleaded guilty to manslaughter. Regarding the first two questions, the court referred to its previous ruling in Nicholas-Taylor v. Commonwealth and affirmed that a Superior Court judge does not have the authority to commit a juvenile defendant charged with murder to the custody of DYS, nor can they sidestep this requirement by committing the juvenile to DYS on a related non-murder offense. Therefore, the answers to the first and second questions were "No." View "Commonwealth v. Padilla" on Justia Law