Justia Massachusetts Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree, aggravated assault and battery by means of a dangerous weapon and armed assault in a dwelling house, holding that there was no Brady violation and that the superior court judge did not err in denying Defendant's second motion for a new trial without an evidentiary hearing on the matter. On appeal, Defendant argued, among other things, that newly discovered evidence of later contradictory testimony by the Commonwealth's key witness proved that the prosecution failed to disclose a plea agreement at the time of trial in violation of Brady v. Maryland, 373 U.S. 83 (1963). The Supreme Judicial Court affirmed and declined to exercise its authority under Mass. Gen. Laws ch. 278, 33E to reduce or set aside the verdict on the murder conviction, holding (1) the judge did not err in finding that Defendant's evidence of a Brady violation did not create a substantial issue warranting an evidentiary hearing; (2) the judge did not abuse his discretion in finding that there was no undisclosed plea deal that would require granting Defendant's second motion for a new trial; and (3) the verdict of murder in the first degree is consonant with justice. View "Commonwealth v. Upton" 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 and related crimes, holding that Defendant was not deprived of a meaningful defense due to the current law on criminal responsibility and that there was no reason to reduce the verdict under Mass. Gen. Laws ch. 28, 33E. At trial, defense counsel unsuccessfully claimed that a mental disorder caused Defendant to suffer delusions that compelled him to plan and commit the murder. On appeal, however, Defendant argued that the law on criminal responsibility made this defense not viable. Therefore, he argued he was deprived of a meaningful defense. The Supreme Judicial Court affirmed, holding (1) the trial judge did not commit reversible error by denying two motions filed by Defendant that advocated for a departure from the current la regarding the defense of a lack of criminal responsibility; and (2) while Defendant suffered from a qualifying mental disorder, he was nonetheless able to conform his actions to the law and to understand the wrongfulness of his actions. View "Commonwealth v. Loya" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court affirmed the judgment of the trial court allowing Defendant's motions to suppress evidence seized during an inventory search of his vehicle and his subsequent statements to police, holding that, where officers are aware that a passenger lawfully could assume custody of a vehicle, it is improper to impound the vehicle without first offering this option to the driver. Defendant, the driver of the vehicle in this case, was properly stopped for a motor vehicle violation and then arrested on an outstanding warrant. The vehicle's sole passenger was a duly licensed and qualified driver. The officers arranged for the vehicle to be impounded without inquiring of Defendant as to whether he preferred to have the passenger take custody of and move the vehicle. After conducting an inventory search the officers discovered Defendant's gun. The motion judge suppressed the gun and Defendant's statements, finding the impoundment to be unreasonable. The Supreme Judicial Court affirmed, holding that suppression was appropriate under the circumstances of this case. View "Commonwealth v. Goncalves-Mendez" on Justia Law

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The Supreme Judicial Court affirmed Defendant's convictions entered by the trial court after a second trial, at which Defendant had different counsel, holding the second trial judge did not err in granting Defendant's motion for a new trial on the basis that Defendant's second attorney provided ineffective assistance of counsel. Defendant was charged with murder in the first degree and related offenses. Then the jury was unable to reach a verdict Defendant's first trial ended in a mistrial. The second trial resulted in Defendant being convicted. Defendant then filed a motion for a new trial, arguing that successor counsel's failure to call or investigate an alibi witness constituted constitutionally ineffective assistance of counsel. The second trial judge allowed the motion, determining that the testimony necessarily would be important to the jury's deliberations. The Supreme Judicial Court affirmed, holding that, under the circumstances, the judge was not unreasonable in finding successor counsel's performance ineffective, and the error was prejudicial. View "Commonwealth v. Diaz Perez" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction of assault and battery causing serious bodily injury, holding that there was no error with respect to the seating of a blind individual on the jury and that the evidence was sufficient to support the conviction. Defendant's conviction stemmed from an incident in which Defendant, without warning, punched the victim in the face. On appeal, Defendant argued, among other things, that his right to a fair and impartial jury was violated because the blind juror that served on the jury was unable to see the physical evidence and had to have the documentary evidence read to him. The Supreme Judicial Court affirmed, holding (1) seating the blind juror was not an abuse of the trial judge's discretion; and (2) the evidence was sufficient to establish beyond a reasonable doubt that Defendant caused serious bodily injury to the victim. View "Commonwealth v. Heywood" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court affirmed Defendant's convictions of discharging a firearm within 500 feet of a building, in violation of Mass. Gen. Laws ch. 269, 12E, and unlawful possession of a firearm, in violation of Mass. Gen. Laws ch. 269, 10(h), holding that that section 12E does not require any mens rea as to the element of discharge and that the trial judge properly declined to instruct on an exemption for temporarily holding a firearm. Defendant's convictions stemmed from an incident in which, while showing a firearm to one of his friends, Defendant accidentally discharged it in a home, shooting his friend through the hand. On appeal, Defendant argued that section 12E includes a mens rea requirement and that the trial judge erred in declining to instruct on an exemption for temporarily holding a firearm. The Supreme Court affirmed, holding (1) section 12E does not require any mens rea as to the element of discharge; and (2) the trial judge did not err in declining to give the requested instruction on the exemption for temporary possession. View "Commonwealth v. Kelly" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court affirmed the order of the motion judge allowing Defendant's motion to suppress, holding that both the patfrisk of Defendant and the search of Defendant's motor vehicle were improper. Two law enforcement officers approached Defendant's vehicle after observing that the vehicle had a cracked windshield and an expired inspection sticker. Defendant got out of his vehicle without being instructed to do so. The officers placed Defendant in handcuffs and conducted a patfrisk of his person. The officers subsequently seized a firearm from the floor in front of the driver's seat. Defendant filed a motion to suppress the evidence, which the motion judge granted. The Supreme Judicial Court reversed, holding (1) Defendant was properly stopped for motor vehicle violations; (2) Defendant's actions, without more, did not justify a patfrisk because they did not establish reasonable suspicion that Defendant was armed and dangerous; and (3) because the search of Defendant's motor vehicle was based on the results of the improper patfrisk, the vehicle search was unconstitutional. View "Commonwealth v. Torres-Pagan" on Justia Law

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The Supreme Judicial Court answered questions reported by a single justice upon Petitioners' petition pursuant to Mass. Gen. Laws ch. 249, 4 asserting claims for mandamus, injunctive, and declaratory relief after the superintendent for each petitioner refused to review Petitioners' petitions for medical parole as submitted regardless of the superintendent's view as to the completeness or adequacy of the petition. Specifically, the Court answered that, when a prisoner submits a written petition for medical parole, the superintendent or sheriff of the facility where the prisoner is incarcerated must consider the petition even if the superintendent or sheriff does not consider the petition complete or adequate. Further, the superintendent or sheriff bears the burden of preparing or procuring a medical parole plan and recommendation as to the release of the prisoner. Lastly, the commissioner, on receipt of the petition and recommendation, is required to provide the prisoner with all supporting documents submitted by the superintendent or sheriff with the recommendation. View "Buckman v. Commissioner of Correction" on Justia Law

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The Supreme Judicial Court affirmed Defendant's convictions and declined to exercise its powers under Mass. Gen. Laws ch. 278, 33E to order a new trial or to reduce the degree of guilt, holding that there was no reason to reverse Defendant's conviction. Defendant was convicted of three counts of murder in the first degree on theories of deliberate premeditation and extreme atrocity or cruelty. The Supreme Judicial Court affirmed the convictions, holding (1) there was sufficient evidence to sustain Defendant's convictions; (2) Defendant's statements to police on the night of his arrest were properly admitted because the statements did not require Miranda warnings and were voluntary; (3) the trial judge did not err by declining to ask a requested question about anti-Hispanic juror bias during voir dire; and (4) there was no basis to grant extraordinary relief under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Tejada" 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 her discretion in denying relief. Petitioner was charged with assault with a dangerous weapon, and, at arraignment, a judge ordered that Petitioner be committed to the state hospital for a determination whether he was competent to stand trial. After he had been committed Petitioner filed this Mass. Gen. Laws ch. 211, 3 petition alleging violations of his due process rights. The single justice denied the petition without holding a hearing. The Supreme Judicial Court affirmed, holding that Petitioner did not demonstrate why he was entitled to review pursuant to Mass. Gen. Laws ch. 211, 3. View "Howell v. Commonwealth" on Justia Law