Justia Massachusetts Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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The Supreme Judicial Court set aside the verdict in this case, vacated Defendant's conviction, and remanded the matter for a new trial, holding that the prosecutor's failure to disclose certain statements and newly discovered evidence required that this matter be remanded.Defendant was convicted of murder in the first degree on a theory of extreme atrocity or cruelty. Prior to trial, the prosecutor failed to disclose testimony by the stepdaughter of the victim describing the victim's last words. Following trial, a forensic pathologist opined that the victim could not have spoken after he had been stabbed. The Supreme Judicial Court reversed the conviction, holding (1) the prosecutor's failure to disclose the stepdaughter's testimony prejudiced Defendant's ability to prepare and present his defense effectively; and (2) the pathologist's opinion likely would have been a real factor in the jury's deliberations. View "Commonwealth v. Rodriguez-Nieves" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree and vacated his conviction of accessory after the fact to murder, holding that, under the circumstances, Defendant could not convicted of joint venture murder in the first degree and of accessory after the fact.Specifically, the Supreme Judicial Court held (1) there was sufficient evidence to prove murder in the first degree; (2) the jury instruction on joint venture liability was a correct statement of the law; (3) while the evidence was sufficient to convict Defendant as an accessory after the fact, because one cannot properly be convicted of a crime and of being an accessory after the fact to the same crime, this conviction must be vacated; (4) the trial judge did not abuse her discretion by failing to order the trial severed; (5) reversible error did not result from the judge's response to a jury question; and (6) there was no reason for the Court to exercise its authority under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Watson" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court remanded this matter to the county court for entry of a judgment allowing Defendant's petition pursuant to Mass. Gen. Laws ch. 211, 3 and ordering that the superior court judge's order hospitalizing Defendant under Mass. Gen. Laws ch. 123, 16(a) be vacated, holding that Defendant's substantive due process rights were violated.A grand jury returned a twelve-count indictment charging Defendant with two counts of armed carjacking and multiple related charges. After a jury-waived trial, Defendant was found not criminally responsible by reason of mental illness. Thereafter, the judge granted the Commonwealth's motion to hospitalize Defendant for evaluation pursuant to section 16(a) for forty days. Defendant filed a petition pursuant to section 3 requesting relief from confinement. A single justice denied the petition. The Supreme Judicial Court remanded the matter, holding that there was no constitutionally adequate justification to temporarily commit Defendant under section 16(a). View "Garcia v. Commonwealth" on Justia Law

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The Supreme Judicial Court exercised its authority under Mass. Gen. Laws ch. 278, 33E to reduce the jury's verdict of murder in the first degree to murder in the second degree, holding that, in light of the circumstances, a verdict of murder in the second degree was more consonant with justice.Defendant was fifteen years old when he killed the victim and had a history of trauma, impaired cognitive abilities, and mental health issues. Defendant was convicted of murder in the first degree and sentenced to life with the possibility of parole after twenty years. On appeal, the Supreme Judicial Court rejected most of Defendant's arguments but agreed that, in the circumstances of this case, there was ground for reducing the verdict from first to second degree murder. View "Commonwealth v. Concepcion" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court affirmed the two judgments of a single justice of the court denying Petitioner's petitions for extraordinary relief pursuant to Mass. Gen. Laws ch. 211, 3, by which Petitioner sought pretrial release or a reduction in bail, holding that the single justice properly denied relief.Petitioner was charged with rape and indecent assault and battery on a person age fourteen or older. Bail was set at $75,000, an amount Petitioner was unable to post bail in this amount. Petitioner moved for immediate release based on the dangers of the coronavirus pandemic. The superior court denied relief. Upon further bail hearing, the judge reduced Petitioner's bail to $25,000. Petitioner was unable to post bail in this amount. Petitioner petitioned a single justice for relief from the two orders, but the justice denied relief. The Supreme Judicial Court affirmed, holding that the single justice did not err or abuse her discretion in denying relief. View "Oquendo v. Commonwealth" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court affirmed Defendant's convictions three counts of murder in the first degree and concluded that Defendant was not entitled to relief under Mass. Gen. Laws ch. 278, 33E, holding that there was no reversible error in the proceedings below.Specifically, the Supreme Judicial Court held (1) the trial judge erred by giving a charge in accordance with Commonwealth v. Rodriguez, 364 Mass. 87 (1973), and Commonwealth v. Tuey, 8 Cush. 1, 2-3, to an individual juror after the jury had been polled, but the error was not prejudicial; (2) some the trial judge's rulings admitting prior bad acts evidence were in error, but the errors were not prejudicial; (3) the judge did not abuse his discretion in admitting coventurer statements; (4) certain remarks made by the prosecutor in opening and closing arguments were in error, but the error was not prejudicial; (5) the trial judge did not err by denying Defendant's motion to suppress; and (6) this Court declines to exercise its authority under Mass. Gen. Laws ch. 278, 33E to order a new trial or direct the entry of verdicts of a lesser degree of guilt. View "Commonwealth v. Chalue" on Justia Law

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The Supreme Judicial Court affirmed the order of the superior court denying Defendant's motion for credit for time he served on a drug conviction that was vacated after the scandal at the State Laboratory Institute in Amherst at the campus of the University of Massachusetts was revealed, holding that Defendant was not entitled to mandatory credit in this case.In 2018, the Supreme Judicial Court ordered the vacated and dismissal with prejudice of thousands of drug convictions that relied on substances tested at the Amherst lab during certain periods of Sonja Farak's employment as a chemist at the lab. That same year, Defendant filed a motion for jail credit in his 2017 criminal case. The judge denied the motion, concluding that Defendant was not entitled to credit because government misconduct at a drug laboratory was not equally compelling to actual innocence. The Supreme Judicial Court affirmed, holding that, under the circumstances of this case, Defendant was not owed credit toward his conviction. View "Commonwealth v. Caliz" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court vacated Defendant's convictions of murder in the first degree and armed assault with intent to murder and affirmed Defendant's conviction of assault and battery by means of a dangerous weapon, holding that the evidence was insufficient to support the murder conviction and the assault and battery by means of a dangerous weapon convictions.At trial, the Commonwealth proceeded on a theory that Defendant had initiated a gunfight with codefendant Keith Williams and was therefore liable for harm to innocent bystanders. The Supreme Judicial Court vacated the convictions in part, holding (1) there was insufficient evidence to convict Defendant of murder in the first degree; (2) the Commonwealth failed to introduce sufficient evidence to support Defendant's conviction of assault and battery by means of a dangerous weapon; and (3) Defendant was not entitled to relief on his remaining allegations of error. View "Commonwealth v. Colas" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court vacated some of Defendant's convictions, holding that the case must be remanded for an evidentiary hearing as to Defendant's motion to suppress and a determination as to whether the first prong of the independent source exception to the exclusionary rule applied.Following two separate jury trials in the Superior Court in Norfolk County and Middlesex County Defendant was convicted of multiple offenses stemming from a burglary spree. Before trial, Defendant moved to suppress evidence seized from his residence during the execution of a search warrant, asserting that the warrant was tainted by discoveries made during an earlier unlawful entry of his residence. The motion judges agreed that the initial entry was unauthorized but that, pursuant to the independent source rule, the evidence was exempt from exclusion as "fruit of the poisonous tree." The Supreme Judicial Court vacated Defendant's Middlesex convictions with the exception of his conviction for intimidation of a witness, holding that because the matter of whether the evidence demonstrated that the detective would not have sought the warrant had the officers not made the initial illegal entry, the matter must be remanded for an evidentiary hearing. View "Commonwealth v. Pearson" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court reversed the decision of the superior court granting a new trial in this criminal case after concluding that the evidence was insufficient to support Defendant's murder conviction on a theory of joint venture felony-murder, holding that granting Defendant's motion for a new trial was error.Defendant was convicted of murder in the first degree, armed robbery, and kidnapping. The court of appeals affirmed. More than forty years later, Defendant filed a motion for a new trial on the murder indictment, arguing that the Commonwealth presented insufficient evidence for the felony-murder conviction. The superior court judge granted the motion. The Supreme Judicial Court reversed, holding (1) the motion judge had authority to consider the sufficiency of the evidence following the Supreme Judicial Court's 33E plenary review on direct appeal; but (2) Defendant was estopped from raising the claim that the evidence was insufficient for the jury to have found that Defendant was a joint venturer in the armed robbery. View "Commonwealth v. Watkins (No. 1)" on Justia Law

Posted in: Criminal Law