Justia Massachusetts Supreme Court Opinion Summaries

Each plaintiff in these consolidated appeals was licensed as a commercial driver and was charged with operating a motor vehicle while under the influence of intoxicating liquor. Each plaintiff admitted to sufficient facts to warrant a finding (CWOF) of guilty, and the judge continued the cases without a finding of guilty. The registrar of motor vehicles determined that the admission and CWOF were a “conviction” and suspended the commercial drivers license of each plaintiff. The Board of Appeal on Motor Vehicle Liability Policies and Bonds affirmed each decision of the registrar. The superior court vacated the Board’s decision in each case, determining that a CWOF is not a conviction as that term is defined in Mass. Gen. Laws ch. 90F. The Board and the registrar appealed. The Supreme Judicial Court vacated the decisions of the superior court and entered judgment in favor of the Board, holding that an admission to sufficient facts to warrant a finding of guilty and the judge’s continuance of the case without a finding of guilty is a “conviction” as that term is defined in Mass. Gen. Laws ch. 90F, 1. View "Tirado v. Bd. of Appeal on Motor Vehicle Liability Policies & Bonds" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on the theory of deliberate premeditation. Defendant’s motion for a new trial was denied. The Supreme Judicial Court affirmed Defendant’s convictions and the denial of his motion for a new trial and discerned no basis to exercise its authority pursuant to Mass. Gen. Laws ch. 278, 33E, holding (1) the trial judge did not err in allowing multiple prior consistent statements; (2) trial counsel was not ineffective in failing to object to the admission of certain evidence and failing to impeach a witness; (3) there was not improper prosecutorial vouching during closing argument that created a substantial likelihood of a miscarriage of justice; and (4) the conviction was viable despite the uncorroborated testimony of a cooperating witness, and newly discovered evidence did not necessitate a new trial. View "Commonwealth v. Lessieur" on Justia Law

After a jury trial, Defendant was convicted of murder in the second degree, unlawful possession of a firearm, unlawful possession of a loaded firearm, and unlawful possession of ammunition. The Supreme Judicial Court affirmed Defendant’s convictions, holding (1) the trial judge’s refusal to grant immunity to two potential defense witnesses did not violate Defendant’s right to a fair trial and due process of law, nor his right to present a complete defense; and (2) the prosecutor did not engage in improper vouching or misstate the evidence in during closing arguments. View "Commonwealth v. Brewer" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on the theory of felony-murder. Defendant appealed, arguing, inter alia, that the trial court erred in its partial denial of his motion to suppress statements he made after being taken involuntarily into the police station. The Supreme Judicial Court affirmed, holding (1) Defendant’s motion to suppress should have been allowed in its entirety because these statements were the inadmissible fruits of an unlawful arrest, but the error did not create a substantial likelihood of a miscarriage of justice; (2) the trial court did not err in denying defense counsel’s motion to withdraw from the case two days before trial; and (3) Defendant’s claim that his counsel provided ineffective assistance lacked merit. View "Commonwealth v. Melo" on Justia Law

After a jury trial, Defendant was convicted of seven indictments charging offenses under Mass. Gen. Laws ch. 265, 13J(b), which imposes criminal penalties on a person who wantonly or recklessly permits bodily injury to a child in his care or wantonly or recklessly permits another to commit an assault and battery causing bodily injury upon such a child. The seven indictments were each based on a distinct injury or set of injuries to the victim. Defendant appealed, contending that the indictments were duplicative. The Supreme Judicial Court reversed all but one of Defendant’s convictions, holding that, to establish multiple violations of Mass. Gen. Laws ch. 265, 13J(b), the Commonwealth may not establish multiple convictions solely by showing multiple injuries to a single child but, rather, must prove either that the defendant engaged in separate and discrete instances of criminal conduct or that multiple victims were harmed as a result of the defendant’s criminal conduct. View "Commonwealth v. Traylor" on Justia Law

After a jury trial, Defendant was convicted of deliberately premeditated murder. Defendant appealed, claiming evidentiary error and prosecutorial misconduct. The Supreme Judicial Court affirmed the conviction and declined Defendant’s request for relief under Mass. Gen. Laws ch. 278, 33E, holding (1) the district judge did not abuse his discretion in admitting evidence of an autopsy photograph; (2) the district judge did not abuse his discretion in admitting a BB rifle together with ammunition that were unrelated to the killing; and (3) the prosecutor did commit impermissible misconduct during closing arguments. View "Commonwealth v. Carney" on Justia Law

After a jury trial, Defendant was convicted of larceny of a motor vehicle. The Commonwealth nol prossed the portion of the indictment that alleged a second or subsequent offense. Defendant filed motions pursuant to Mass. R. Crim. P. 30 and, before the motions were acted on, filed a Mass. Gen. Laws ch. 211, 3 petition, arguing that the Commonwealth could not nol pros only a portion of the indictment. A single justice of the Supreme Judicial Court denied Defendant’s petition for extraordinary relief. The Supreme Judicial Court affirmed, holding that Defendant had an adequate alternative remedy by way of appeal. View "Carrington v. Commonwealth" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree and aggravated rape. The Supreme Judicial Court affirmed in part and reversed in part, holding (1) the evidence was insufficient to support Defendant’s conviction of aggravated rape; (2) the trial court did not err in admitting opinion testimony of a criminalist with the State police crime laboratory; (3) the trial court erred in admitting an autopsy report prepared by a medical examiner who did not testify at trial and in admitting the testimony of a substitute medical examiner, but the admission of this evidence did not create a substantial likelihood of miscarriage of justice; (4) the trial court did not err in admitting a witness’s testimony that she recognized Defendant as a patron of a bar in which the victim was seen on the night of her death; (5) the prosecutor committed error during closing arguments, but Defendant was not prejudiced by the errors; and (6) the trial judge did not err in declining to instruct the jury in accordance with Defendant’s proposed instruction on third-party culprit evidence. View "Commonwealth v. Scesny" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on the theory of extreme atrocity or cruelty. The Supreme Judicial Court affirmed the convictions, holding that the trial judge did not err in (1) admitting into evidence a cellular telephone text message sent by the victim; (2) granting the Commonwealth leave to present general evidence that Defendant made statements - which were previously suppressed - to impeach proffered evidence that he was noncommunicative; (3) excluding the testimony of a defense expert witness; and (4) instructing the jury on diminished capacity. View "Commonwealth v. Mulgrave" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on a theory of deliberate premeditation. Defendant filed a motion for a new trial, asserting that his trial counsel provided ineffective assistance. The trial judge denied the motion. The Supreme Judicial Court vacated Defendant’s conviction and remanded for a new trial, holding that Defendant’s counsel did not prepare for trial in an adequate manner and that counsel’s deficient performance at trial, where Defendant’s defense was presented “poorly and incompletely,” created a substantial likelihood of a miscarriage of justice. View "Commonwealth v. Alcide" on Justia Law