Justia Massachusetts Supreme Court Opinion Summaries

Defendant was convicted of two counts of murder in the first degree. Defendant was sixteen years old at the time of the crimes. Defendant was sentenced in 1994 to two consecutive sentences of life without the possibility of parole. At the time of his sentencing, the distinction between consecutive and concurrent sentences had little practical impact, but the Supreme Judicial Court’s subsequent decisions in Diatchenko v. District Attorney for the Suffolk Dist. and Commonwealth v. Brown changed that. In the wake of the Court’s decisions in Diatchenko and Brown, Defendant moved for resentencing. The trial court judge concluded that Defendant was entitled to a resentencing proceeding on the issue of whether the sentences should be imposed consecutively or concurrently. The Supreme Judicial Court affirmed, holding that a trial court judge, in resentencing a juvenile offender originally sentenced to multiple consecutive terms of life without the possibility of parole, may conduct a sentencing hearing to consider resentencing the juvenile offender to concurrent terms. Remanded. View "Commonwealth v. Costa" on Justia Law

After a jury trial, Defendant was convicted of rape, unarmed robbery, and kidnapping. The appeals court affirmed. Defendant was subsequently paroled, but his parole was revoked when he pleaded guilty to larceny over $250. In 2013, Defendant filed a postconviction motion under Mass. Gen. Laws ch. 278A, 3 for forensic or scientific analysis of certain evidence presented at his trial and for discovery regarding the location of other items referenced at trial but not admitted into evidence. Specifically, Defendant sought DNA testing of the evidence presented at trial and potential DNA testing of the remaining items at issue. A judge denied Defendant’s motion. The Supreme Judicial Court reversed the judge’s order denying Defendant’s section 3 motion except insofar as it denied Defendant’s request for discovery, holding (1) Defendant met the requirements of Mass. Gen. Laws ch. 278A, 3; (2) the judge erred in determining that Defendant was required to establish the existence of biological material on the evidence admitted into evidence; (3) the judge properly denied Defendant’s request for discovery; and (4) the judge must make findings of fact and conclusions of law regarding whether Defendant satisfied Mass. Gen. Laws. ch. 278A, 7(b)(2), (3), (5), and (6). Remanded. View "Commonwealth v. Clark" on Justia Law

After a jury trial, Defendant was convicted of deliberately premeditated murder. On appeal, Defendant filed a motion for a new trial and a motion for funds for an investigator. The trial judge denied the motions without a hearing and also denied Defendant’s motion for reconsideration. The Supreme Judicial Court affirmed the convictions and the denial of Defendant’s postconviction motions, holding (1) the judge did not abuse his discretion in concluding that Defendant failed to meet his burden of proof when he denied Defendant’s claim of ineffective assistance of counsel as contained in his motions for a new trial and for reconsideration; and (2) the judge’s conclusion that Defendant’s claim of newly discovered evidence could not be ascertained was neither erroneous nor an abuse of discretion. View "Commonwealth v. Gorham" on Justia Law

In 2002, Defendant was convicted of indecent assault and battery on a child under the age of fourteen, which qualifies as a “sexual offense” under Mass. Gen. Laws ch. 123A, 1. In 2013, Defendant was indicted for failure to register as a sex offender, subsequent offense. Defendant was unable to post bail on his pending indictment and remained in custody solely for that reason until trial. In 2014, the Commonwealth filed a petition pursuant to Mass. Gen. Laws ch. 123A, 12 to civilly commit Defendant as a sexually dangerous person (SDP). Defendant moved to dismiss the petition, claiming that the district attorney was not authorized to file a petition against him under the circumstances. The trial judge denied the motion, concluding that section 12 contemplates the SDP commitment of persons previously convicted of a sexual offense who are currently serving a criminal sentence or who face pending charges and are awaiting trial. The Supreme Judicial Court reversed, holding that the Commonwealth may not file an SDP petition under section 12 against a person such as Defendant, who is in custody only because he is awaiting trial, unless a judge has found the defendant incompetent to stand trial. View "Commonwealth v. Libby" on Justia Law

Defendant was charged with one count of assault and battery on a family member. Prior to Defendant’s release upon arraignment, the Commonwealth submitted a preliminary written statement pursuant to Mass. Gen. Laws ch. 276, 56A, alleging that domestic abuse occurred immediately prior to or in conjunction with Defendant’s charged offense. The judge declined to rule that domestic abuse was alleged in connection with the charged offense and reported the case to the Appeals Court, opining that section 56A in part violated Defendant’s constitutional guarantee of due process and separation of powers by interfering with the judicial function. The case was entered in the Appeals Court, and the Supreme Judicial Court granted Defendant’s application for direct appellate review. The Supreme Judicial Court responded to the judge’s report by holding that section 56A requires that before a judge makes a “written ruling that abuse is alleged in connection with the charged offense,” the judge must inquire into and be satisfied that there is an adequate factual basis for the abuse allegations made by the Commonwealth. View "Commonwealth v. Dossantos" on Justia Law

A Massachusetts grand jury issued indictments against Defendants, Nickoyan Wallace and Timi Wallace, accusing them of murder. Defendants were in federal custody from 2000 until 2009. Not until 2009 did prosecutors initiate the necessary steps to gain custody of Defendants from federal prison authorities under the Interstate Agreement on Detainers. Defendants were subsequently arraigned in superior court. Defendants filed motions to dismiss, alleging that the Commonwealth’s delay in obtaining custody of them from federal prison authorities impermissibility affected their right to a speedy trial. A superior court judge found that Timi’s right to a speedy trial had not been violated but that of Nickoyan had. The Appeals Court affirmed in part and reversed in part, concluding that the Commonwealth had not violated the speedy trial right of either defendant. The Supreme Judicial Court affirmed the trial court’s decision to deny Timi’s motion and to allow Nickoyan’s motion, holding that, under the circumstances of this case, Nickoyan’s right to a speedy trial was violated under the circumstances of this case but that Timi’s was not. View "Commonwealth v. Wallace" on Justia Law

Defendant was indicted on four counts of forcible rape of a child and four counts of indecent assault and battery on a child under the age of fourteen. Defendant filed a motion to suppress statements he made to police officers during the course of two interviews, the first being prearrest and the second following his arrest. Defendant was advised of his Miranda rights at the beginning of both interviews, but those rights were not accurately explained. The district court suppressed both statements. The Supreme Court reversed the suppression of the prearrest statement but affirmed the suppression of the postarrest statement, holding (1) the totality of the circumstances supports the conclusion that Defendant’s prearrest statements were voluntary; and (2) the Commonwealth failed to meet its burden of proving that Defendant waived his right to consult with counsel prior to giving his postarrest statements. View "Commonwealth v. Libby" on Justia Law

Defendant was convicted of mayhem and resisting arrest. Defendant appealed, arguing, among other things, that the judge abused her discretion in denying Defendant’s requested cross-racial and cross-ethnic eyewitness identification jury instruction where two of the three eyewitnesses were Caucasian and Defendant was a “dark-skinned Hispanic of Dominican decent.” This case was tried before the Supreme Judicial Court issued its opinion in Commonwealth v. Gomes, where the Court prospectively required that a jury instruction on cross-racial eyewitness identification be given in these circumstances. The Supreme Judicial Court affirmed, holding (1) the judge did not abuse her discretion in declining to give Defendant’s requested cross-racial and cross-ethnic instruction; (2) in criminal trials that commence after the issuance of this opinion, a cross-racial instruction should always be included when giving the model eyewitness identification instruction unless the parties agree that there was no cross-racial identification; (3) the admission of the three in-court eyewitness identifications in this case did not create a substantial risk of a miscarriage of justice; and (4) although the judge erred in instructing the jury regarding consciousness of guilt, the error was not prejudicial. View "Commonwealth v. Bastaldo" on Justia Law

Defendant was convicted of assault and battery for spanking his daughter, who was then almost three years old. Defendant appealed, arguing that the evidence was insufficient to sustain his conviction in light of the parental privilege to use force in disciplining a minor child. The appeals court affirmed, concluding that Defendant’s conduct fell outside of the parental privilege defense. The Supreme Judicial Court reversed, holding (1) a parent or guardian may not be subjected to criminal liability for the use of force against a minor child provided that the force used is reasonable, the force is reasonably related to the purpose of safeguarding or promoting the welfare of the minor, and the force does not create a substantial risk of causing physical harm or severe mental distress; and (2) the evidence adduced at Defendant’s trial was insufficient to sustain a conviction of assault and battery. View "Commonwealth v. Dorvil" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on the theory of extreme atrocity or cruelty. Defendant appealed. While his appeal was pending, Defendant filed a motion for a new trial, arguing that his trial counsel provided ineffective assistance and that the trial court erred in instructing the jury. The judge granted Defendant’s motion for a new trial, concluding that Defendant’s trial counsel was ineffective in failing to fully investigate, present, and argue evidence of Defendant’s mental condition. The Supreme Judicial Court reversed, holding that the judge erred in ruling that counsel’s strategic choice to forgo further investigation of Defendant’s mental condition and to present only an intoxication defense was manifestly unreasonable. View "Commonwealth v. Kolenovic" on Justia Law