Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court vacated Defendant's convictions for five counts of trafficking a person for sexual servitude and a second and subsequent offense of possession of a class A substance with intent to distribute, holding that the conflict of interest inherent in counsel's bigotry against persons of Defendant's faith and race deprived Defendant of his right to effective assistance of counsel.Defendant, a Black man of the Muslim faith, was appointed counsel who openly shared his hatred of and bigotry against people of the Muslim faith and his racism against Black persons. Counsel advised Defendant to accept a plea deal, which Defendant did. Defendant later filed a motion to withdraw his guilty plea and for a new trial, arguing that his counsel had an actual conflict of interest. The motion judge denied the motion. The Supreme Judicial Court reversed and remanded the case for a new trial, holding that Defendant met his burden to establish that counsel's representation of him was impaired by an actual conflict of interest. View "Commonwealth v. Dew" on Justia Law

The Supreme Judicial Court vacated Defendant's conviction of carrying a firearm without a license and his sentence of eighteen months in a house of correction, holding that the Commonwealth did not demonstrate beyond a reasonable doubt that Defendant knowingly, intelligently, and voluntarily waived his Miranda rights, and Defendant did not waive this issue.In a pretrial motion, Defendant filed a motion to suppress based on the alleged inadequacy of the Miranda warnings provided to him in Spanish. The motion judge denied the motion after finding that Defendant was given "the full complement of Miranda warnings" in English and in Spanish. After he was convicted and the convictions were affirmed on appeal Defendant filed a postconviction motion for a new trial, which the motion judge denied following a hearing. The appeals court affirmed. The Supreme Judicial Court vacated the conviction, holding (1) Defendant did not waive the issue of whether Miranda warnings were properly given to him in Spanish; and (2) the admission of Defendant's post arrest statements was error. View "Commonwealth v. Delossantos" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of voluntary manslaughter and his sentence of ten to twelve years in prison, holding that the trial errors detected in the underlying proceedings did not, either individually or in combination, create a substantial risk of a miscarriage of justice.Defendant was charged with murder in the first degree and, after a jury trial, convicted of the lesser charge of voluntary manslaughter. On appeal, Defendant argued that rap lyrics he had written were erroneously admitted at trial, that the Commonwealth improperly commented on his rearrest silence, that one of the deliberating jurors was not fair and impartial, and that the jury instructions misstated the law on self-defense. The Supreme Judicial Court affirmed, holding (1) there was error in the trial court's decision to admit Defendant's lyrics, but Defendant was not prejudiced; (2) referencing Defendant's pre-arrest silence was error, but there was no substantial likelihood of miscarriage of justice; but (3) in the context of the entire trial, there was no substantial risk of a miscarriage of justice. View "Commonwealth v. Correia" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on theories of both deliberate premeditation and extreme atrocity or cruelty, holding that there was no error in the underlying proceedings or in the verdict.On appeal, Defendant argued, among other things, that the district court erred in denying his motion to suppress the evidence recovered pursuant to a search warrant following a police trooper's examination of Defendant's vehicle, which was visibly parked in the driveway leading up to his house. The Supreme Judicial Court affirmed, holding (1) because Defendant's vehicle was not parked within the curtilage of his home the trooper's observations of the vehicle did not constitute a search for constitutional purposes; and (2) there was no reason for this Court to exercise its authority under Mass. Gen. Laws ch. 278, 33E to reduce the verdict or order a new trial. View "Commonwealth v. Wittey" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on the theory of deliberate premeditation but vacated his conviction of murder in the first degree on a theory of felony-murder, holding that the felony-murder conviction was improper.Defendant was convicted of murder in the first degree on theories of deliberate premeditation and felony-murder, with aggravated kidnapping as the predicate felony. In this appeal, consolidated with the appeal of his motions for a new trial and for reconsideration, Defendant argued, and the Commonwealth conceded, that the conviction of murder in the first degree on a theory of felony-murder was improper because the predicate felony of aggravated kidnapping did not exist at the time of the killing. The Supreme Court vacated Defendant's felony-murder conviction and otherwise affirmed, holding (1) Defendant's conviction of felony-murder lacked sufficient evidence to support it; and (2) Defendant was not entitled to relief on his remaining allegations of error. View "Commonwealth v. Samia" on Justia Law

The Supreme Judicial Court affirmed the judgment of the county court denying the Commonwealth's petition filed under Mass. Gen. Laws ch. 211, 3 seeking relief from a superior court judge's denial of the Commonwealth's motion to disqualify Rosemary Scapicchio, Defendant's appellate counsel, on the ground that she had a conflict of interest, holding that the single justice did not err or abuse his discretion in denying the motion.Defendant was convicted of murder in the first degree. Later, represented by Scapicchio, Defendant filed a motion for a new trial alleging ineffective of counsel. Thereafter, Scapicchio represented Michael Barros at a hearing in an unrelated criminal case. The Commonwealth moved to disqualify Scapicchio on the grounds that her representation of both Defendant and Barros gave rise to a conflict of interest. The superior court denied the motion. The Commonwealth then filed the petition at issue. The single justice denied relief without reaching its merits. The Supreme Judicial Court affirmed, holding that the single justice neither erred nor abused his discretion by denying the petition. View "Commonwealth v. Monteiro" on Justia Law

The Supreme Judicial Court affirmed the order of a single justice of the court denying Petitioner's petition filed pursuant to Mass. Gen. Laws ch. 211, 3, holding that nothing in Petitioner's petition required exercise of the court's extraordinary power of general superintendence.Petitioner, who was indicted for murder in the first degree and related offenses, filed a document entitled "Notice of Default and Opportunity to Cure re affidavit -- 'Writ of Quo Warranto' re Proof of Claim/Jurisdiction'" claiming that the courts of the Commonwealth lacked jurisdiction over him. The superior court judge denied the petition. Thereafter, Petitioner brought this petition seeking review. A single justice denied the petition. The Supreme Judicial Court affirmed, holding that the single justice was warranted in denying this Mass. Gen. Laws ch. 211, 3 petition. View "Wallace v. Commonwealth" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of one count of murder in the first degree on the theories of deliberate premeditation, extreme atrocity or cruelty, and felony murder, holding that there was no prejudicial error or reason to grant relief under Mass. Gen. Laws ch. 278, 33E.Specifically, the Supreme Judicial Court held (1) the trial judge did not abuse his discretion in finding Defendant competent to stand trial over defense counsel's objections; (2) Defendant was not prejudiced by the jury instructions concerning the consequences of a verdict of not guilty due to lack of criminal responsibility; and (3) the jury were entitled to conclude that Defendant was criminally responsible, and this Court declines to reduce the degree of guilt, order a new trial, or grant other relief under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Beatty" on Justia Law

The Supreme Judicial Court held that a defendant who has been serving the incarcerated portion of an illegal sentence imposed by the appellate division of the superior court has the same double jeopardy protections as a defendant who has been serving the incarcerated portion of an illegal sentence imposed by a single superior court judge.Defendant was convicted of indecent assault and battery. The appellate division revised Defendant's sentence by reducing the period of incarceration on two counts to from four to six years in prison. After it was discovered that Defendant's sentence was illegal the appellate division reversed the incarcerated portion of Defendant's sentence to concurrent terms of from five to six years. Defendant filed a petition under Mass. Gen. Laws ch. 211, 3 arguing that his resentence violated common-law principles of double jeopardy. The single justice denied the petition. The Supreme Judicial Court reversed, holding (1) when sufficient time has lapsed even an illegal sentence becomes final, and double jeopardy principles preclude the State from making upward adjustments to the sentence; and (2) Defendant was entitled to judgment on his petition. View "Martin v. Commonwealth" on Justia Law

In this action brought by the Commonwealth seeking relief from a trial court order requiring it to disclose information regarding a confidential informant the Supreme Judicial Court held that the motion judge in this case abused her discretion by failing to conduct the two-stage inquiry applicable to motions for disclosure of information subject to the Commonwealth's assertion of the informant privilege.After an informant notified police that Defendant was dealing crack cocaine Defendant was charged with a drug-trafficking offense and unlicensed operation of a motor vehicle. Defendant moved for disclosure of the name and address of the informant, as well as details relating to the informant's credibility. The motion judge allowed the motion. The Supreme Judicial Court reversed, holding that (1) the motion judge abused her discretion by failing to conduct the two-stage inquiry applicable to motions for disclosure of information subject to the Commonwealth's assertion of the informant privilege; and (2) the information sought was not sufficiently material or relevant to the defense to warrant the Commonwealth's assertion of the privilege. View "Commonwealth v. Gandia" on Justia Law