Justia Massachusetts Supreme Court Opinion Summaries

A woman was charged in connection with the death of her eleven-month-old niece, who had been left in her care for several hours. The infant, previously healthy, was found unresponsive, and surveillance footage captured the sounds of crying and a sequence of thuds before the defendant called 911. Medical personnel observed a bruise on the child’s head, and subsequent hospital treatment and autopsy revealed acute subdural hematoma, brain swelling, and multiple bruises. Expert witnesses for the prosecution testified that the injuries were consistent with abusive head trauma, while the defense experts posited that the child suffered from chronic subdural bleeding and that a minor bump could have caused a rebleed.The defendant was indicted for first-degree murder in the Massachusetts Superior Court. Prior to trial, the judge conducted a Daubert-Lanigan hearing on the admissibility of expert testimony regarding abusive head trauma. The judge ruled experts could testify that the injuries were “consistent with” abusive head trauma but could not state that such trauma definitively caused the death. Testimony was also limited regarding the causation of such trauma by short falls. At trial, the jury convicted the defendant of involuntary manslaughter under theories of battery and wanton or reckless conduct. The defendant’s motions for a required finding of not guilty were denied.On appeal, the Supreme Judicial Court of Massachusetts reviewed whether there was sufficient evidence for conviction and if the trial judge abused discretion in admitting expert testimony. The Court held the evidence was sufficient for a rational jury to find the elements of involuntary manslaughter beyond a reasonable doubt. The Court also held that the trial judge did not abuse discretion in admitting expert testimony that the injuries were “consistent with” abusive head trauma, finding the diagnosis generally accepted in the medical community. The judgment of conviction was affirmed. View "Commonwealth v. Hsu" on Justia Law

The case concerns a fatal incident that took place in November 2020. The defendant, along with two associates, was involved in a series of events that led to the stabbing death of a marijuana dealer at the dealer’s apartment. The defendant and one associate entered the victim’s home, while the third person waited outside in a car. After the stabbing, the defendant and his associate fled with bags containing marijuana and other items, and quickly left the scene. Evidence indicated that the defendant discarded bloody clothing and attempted to evade authorities by purchasing a bus ticket under a false identity. No murder weapon was recovered, but forensic evidence linked the defendant to the crime.The case was tried in the Massachusetts Superior Court. The defendant and the associate who waited outside were both charged, while the direct participant in the stabbing died before trial. The defendant was convicted of armed robbery and murder in the first degree under a felony-murder theory. The associate was convicted as an accessory after the fact, and that conviction was affirmed by the Massachusetts Appeals Court. The defendant appealed, arguing that the evidence was insufficient for felony-murder and that the trial judge should have instructed the jury on larceny as a lesser included offense.The Supreme Judicial Court of Massachusetts reviewed the case. It held that the evidence was sufficient for a rational jury to find the defendant guilty of felony-murder predicated on armed robbery, either as a principal or joint venturer. The court also found that the trial judge was not required to instruct the jury on larceny, given the defendant’s trial strategy and the absence of a request for such an instruction. The defendant’s convictions and the judgments of the lower court were affirmed. View "Commonwealth v. Henderson" on Justia Law

The defendant pleaded guilty in 1995 to two counts of second-degree murder and several related charges after confessing to the shooting deaths of Tracy Brown and Celine Kirk in Boston. Evidence included ballistics matching a weapon used in a prior shooting, witness identification, and a confession detailing facts only the perpetrator would know. The plea resulted in two consecutive life sentences with parole eligibility and concurrent sentences for other charges.Prior to this appeal, the defendant filed multiple motions in the Massachusetts Superior Court to withdraw his guilty pleas, arguing ineffective assistance of counsel and issues with discovery. These motions were denied, and the Massachusetts Appeals Court affirmed the denials. In 2020, the defendant filed another motion for a new trial, asserting that undisclosed exculpatory evidence and newly discovered evidence from the investigation into Detective John Mulligan's murder, as well as alleged police misconduct and a protective order restricting access to certain materials, undermined the voluntariness of his plea and counsel’s effectiveness. After an evidentiary hearing, the Superior Court judge denied the motion, finding no material prejudice and that the defendant’s decision to plead guilty was rational given the strong evidence against him.The Supreme Judicial Court of Massachusetts reviewed the case on direct appellate review. It held that the defendant failed to demonstrate a reasonable probability that he would have rejected the plea offer had he known of the undisclosed or newly discovered evidence, and did not show that rejecting the plea would have been rational. The court found no nexus between alleged police misconduct and the investigation of the defendant’s case, and concluded the confession was voluntary. The order denying the motion to vacate the guilty pleas and for a new trial was affirmed. View "Commonwealth v. Hood" on Justia Law

An individual was accused by his stepdaughter of multiple incidents of sexual abuse when she was eleven years old. He denied these allegations, but in 2017, a jury convicted him of two counts of indecent assault and battery on a child under fourteen. These convictions required him to register as a sex offender. Over the next several years, the relevant state board classified him multiple times as a level two sex offender, with each classification subject to objections, appeals, or procedural errors that resulted in vacatur or amendment. In his most recent classification proceeding, he requested funds for an expert to testify about the relationship between repetitive sexual offenses and dangerousness, particularly whether current research supported using multiple offenses as a factor in assessing his future dangerousness. The hearing examiner denied this request, finding the proposed testimony would not be unique to his case. The examiner then found by clear and convincing evidence that he posed a moderate risk of reoffense and dangerousness, ordering registration as a level two offender.He sought judicial review in the Massachusetts Superior Court, which affirmed both the substantive classification decision and the denial of expert funds. He timely appealed, and the Supreme Judicial Court of Massachusetts granted direct appellate review.The Supreme Judicial Court of Massachusetts held that the denial of funds for expert testimony was an abuse of discretion. The court found that the request for expert funds was sufficiently specific and relevant to the novel application of a regulatory factor assessing dangerousness based on multiple offenses, especially given recent changes in the application of similar factors and the lack of clear empirical support. The court vacated the Superior Court judgment and remanded the matter to the board for further proceedings, including granting the request for expert funds. View "Doe v. Sex Offender Registry Board" on Justia Law

The case concerns a fatal stabbing that occurred outside a shelter where both the defendant and the victim resided. On the night of the incident, the defendant reported to shelter staff that the victim was intoxicated and behaving aggressively. After this report, both men left the shelter and walked toward the street, with shelter staff anticipating a potential fight due to shelter rules against fighting on the premises. Surveillance footage captured part of the altercation in which the defendant stabbed the victim multiple times, resulting in the victim’s death. The defendant claimed self-defense, arguing that the victim was the first to use deadly force by attacking him with a screwdriver.The case was tried in the Massachusetts Superior Court, where the defendant was convicted by a jury of murder in the first degree on a theory of deliberate premeditation. The defense requested, but later withdrew, an instruction on voluntary manslaughter by sudden combat. After his conviction, the defendant filed a motion for a new trial, arguing that his counsel was ineffective for not introducing evidence of the victim’s prior violent conduct under Commonwealth v. Adjutant, and that the trial judge should have instructed the jury on voluntary manslaughter by sudden combat. The motion was denied by a different Superior Court judge, who found counsel’s decision strategic and not manifestly unreasonable.The Supreme Judicial Court of Massachusetts reviewed both the direct appeal and the denial of the motion for a new trial. It held that trial counsel’s decision not to introduce evidence of the victim’s prior bad acts was not manifestly unreasonable, as its probative value was limited and it would have allowed the Commonwealth to introduce the defendant’s own violent history. The Court also found that the evidence did not warrant a sudden combat manslaughter instruction. The Supreme Judicial Court affirmed the conviction and the denial of the motion for a new trial. View "Commonwealth v. Ramos" on Justia Law

Two separate criminal cases involved the seizure of cell phones from defendants following their arrests for offenses involving the sexual exploitation of minors. In one case, police responded to a 911 call in which a child reported repeated sexual assaults by a convenience store clerk, who had allegedly photographed the victim’s genitals. The suspect was arrested and his cell phone was seized as potential evidence. In the other case, a foster parent was accused by two children of repeated sexual abuse, including using his cell phone to photograph and display sexually explicit images. He was arrested after being contacted on the same cell phone, which was then seized.In both cases, the Commonwealth delayed seeking warrants to search the seized phones—109 days in the first case and 123 days in the second—citing investigative workloads and the time required to complete lengthy affidavits. The Superior Court in each instance allowed the defendants’ motions to suppress the evidence obtained from the phones, finding that the delays rendered the continued seizures unreasonable under Massachusetts law, relying on Commonwealth v. White, which had found a 68-day delay unreasonable under its facts. The Commonwealth sought interlocutory review. In the Diaz case, the Appeals Court affirmed suppression, and the Supreme Judicial Court of Massachusetts granted further appellate review. Both cases were ultimately reviewed together by the Supreme Judicial Court of Massachusetts.The Supreme Judicial Court of Massachusetts held that, under the totality of the circumstances, the delays did not make the continued seizures unreasonable. The Court emphasized that when police have probable cause and the device is itself evidence of the crime, the government’s interest in retaining the phone may outweigh the defendant’s possessory interest, especially if the defendant does not seek return of the phone and there is no evidence of particular hardship. The orders suppressing the evidence were reversed and the cases remanded. View "Commonwealth v. Solis" on Justia Law

Police officers in Boston were investigating a recent robbery and shooting at an apartment complex. The victim described the suspect as a tall man in black clothing with a camouflage mask and a southern accent. Surveillance footage from the complex showed an individual whose clothing and appearance matched this description, including a distinctive hat, jacket, and sneakers. Additional footage the next day showed the same individual without a mask, reinforcing the identification. Twelve days later, a housing authority officer monitoring live surveillance spotted a person matching the suspect’s description, and police responded to the location.A Suffolk County grand jury indicted the defendant for armed robbery and drug offenses. The defendant moved to suppress evidence—money and drugs—that he discarded while fleeing from police, arguing that his seizure was not supported by reasonable suspicion. The Superior Court judge denied the motion, finding reasonable suspicion existed once the defendant was apprehended after his flight. At trial, the Commonwealth did not proceed on the robbery charge, and a jury convicted the defendant of possession with intent to distribute a controlled substance.The Appeals Court affirmed the conviction, concluding that reasonable suspicion justified the seizure. On further appellate review, the Supreme Judicial Court of Massachusetts held that the defendant was seized when police from multiple directions began to pursue him in response to his flight, which occurred before he abandoned the drugs. The court concluded that, at that moment, the officers had reasonable suspicion, based on specific and articulable facts from the ongoing investigation and video evidence, to believe the defendant had committed the robbery. Therefore, the drugs were not the fruit of an unlawful seizure, and the denial of the motion to suppress was affirmed. View "Commonwealth v. Palmer" on Justia Law

The case involves a woman who stabbed her two young sons to death in February 2018. Prior to the murders, she had been perceived as a caring mother with no documented mental illness, but she became obsessed with conspiracy theories, particularly the Illuminati, and exhibited increasingly paranoid behavior. After the killings, she provided conflicting accounts to police, alternately blaming others and describing ritualistic motives related to her delusions. Evidence at trial included her statements, the crime scene, and her behavior before and after the murders.The defendant was indicted in the Superior Court on two counts of first-degree murder and one count of willfully misleading police officers. She filed notice of intent to rely on a defense of lack of criminal responsibility. At trial, her expert witness examined her medical records from MCI-Framingham and WRCH, which documented her mental health treatment and diagnoses post-arrest. The trial judge excluded these medical records from evidence, applying a common-law evidentiary rule about expert testimony and determining they could only be referenced if the Commonwealth opened the door during cross-examination. The jury convicted her on both murder counts.On appeal to the Supreme Judicial Court of Massachusetts, the defendant argued that exclusion of her medical records impeded her criminal responsibility defense and that the prosecutor’s closing argument was improper. The Supreme Judicial Court held that the trial judge erred in excluding the medical records, which were admissible under G. L. c. 233, § 79, and that this exclusion constituted prejudicial error. The Court vacated the convictions, set aside the verdicts, and remanded the case for a new trial. The Court also addressed issues regarding the prosecutor’s closing argument for guidance on retrial. View "Commonwealth v. Sanders" on Justia Law

The defendant was convicted by a jury of murder in the first degree, resisting arrest, and possession of a class B substance after fatally stabbing his live-in girlfriend in their apartment. The incident occurred after a dispute, and the victim was found dead in the building’s entryway. The scene contained significant blood evidence, and the defendant was found in the apartment with both himself and the couch covered in blood. At trial, the defendant admitted to killing the victim but claimed he acted in self-defense while under the influence of PCP, arguing he only used excessive force and lacked premeditated intent. The medical examiner determined the victim suffered multiple sharp-force injuries, some consistent with defensive wounds.Following a mistrial in 2020 due to the COVID-19 pandemic, a second trial in 2021 resulted in the defendant’s conviction in the Hampden Superior Court. The court sentenced him to life imprisonment without parole for murder and concurrent sentences for the other offenses. The defendant later moved for a new trial, arguing ineffective assistance of counsel based on four grounds: failure to investigate his PTSD, failure to investigate the victim’s violent history, failure to introduce evidence of the victim’s recent drug use, and failure to introduce expert testimony corroborating his defensive injury. The motion was denied after a nonevidentiary hearing.The Supreme Judicial Court of Massachusetts reviewed both the direct appeal and the denial of the motion for a new trial. The court held that there was no reversible error and that counsel’s performance did not create a substantial likelihood of a miscarriage of justice. The court also declined to reduce the murder conviction to a lesser degree under G. L. c. 278, § 33E. The convictions and the denial of a new trial were affirmed. View "Commonwealth v. Dorsey" on Justia Law

The defendant was convicted of several firearm-related offenses, including carrying a firearm without a license and possession of ammunition without a firearm identification card. At sentencing, the Commonwealth sought to enhance the defendant’s sentence based on prior convictions, including a 2002 drug conviction. To prove the prior conviction, the Commonwealth introduced a nine-page copy of a District Court docket sheet. The copy bore the court’s seal and a stamped signature, but lacked a written certification attesting it was a true and accurate copy of the original. The defense did not object to the docket sheet’s admission at trial.After the jury trial, the defendant was found guilty of the underlying firearm charges in the Superior Court Department, and following a jury-waived trial on the sentencing enhancements, the judge found him guilty of the enhancement under G. L. c. 269, § 10G (a). The defendant was sentenced to five to seven years in State prison under this enhancement. The Appeals Court affirmed the convictions. The Supreme Judicial Court of Massachusetts then granted further appellate review to consider whether the docket sheet was properly authenticated and, if not, whether its admission created a substantial risk of a miscarriage of justice.The Supreme Judicial Court held that the copy of the District Court docket sheet was not properly authenticated, as it did not meet the requirements for attestation set forth in the relevant rules and statutes. However, the Court concluded that the error did not create a substantial risk of a miscarriage of justice. The Court reasoned that the document had many indicia of reliability, the defendant did not dispute the conviction, and the Commonwealth could have remedied the error if it had been identified at trial. The defendant's conviction under G. L. c. 269, § 10G (a) was therefore affirmed. View "Commonwealth v. Shaw" on Justia Law