Justia Massachusetts Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of mayhem and assault and battery by means of a dangerous weapon causing serious bodily injury. The Appeals Court affirmed, concluding that Defendant’s convictions were not duplicative. The Supreme Judicial Court affirmed, holding (1) while Defendant cannot be convicted of both mayhem and assault and battery by means of a dangerous weapon causing serious bodily injury unless the convictions rest on separate and distinct acts, Defendants actions here did not form but one act; and (2) therefore, Defendant’s convictions were not duplicative. View "Commonwealth v. Figueroa" on Justia Law

Christopher Kostka’s twin brother, Timothy Kostka, was indicted on charges of murder in the first degree and armed home invasion. The Commonwealth filed a motion to compel Christopher to provide a saliva sample from which it may obtain Christopher’s DNA, arguing that the DNA sample was necessary in order to determine whether Christopher was the identical or fraternal twin of Timothy. The trial judge allowed the motion, concluding that the DNA sample was relevant to establishing whether the DNA found under the victim’s fingernails matched Christopher’s and that a sample of Christopher’s DNA would “probably” provide evidence relevant to the question of Timothy’s guilt. Christopher refused to comply with the order to compel, and a judgment of contempt was entered against him. The Supreme Judicial Court reversed, holding that Christopher’s DNA was not shown to be sufficiently relevant or important to the question of Timothy’s guilt or innocence so as to outweigh the constitutional rights of Christopher, an uncharged third party in the criminal proceeding. View "Commonwealth v. Kostka" on Justia Law

Defendant was convicted of operating a motor vehicle while under the influence of liquor (OUI). Before trial, Defendant, along with sixty-one other defendants in other OUI cases, moved to exclude admission of breath test evidence derived from the use of the Alcotest 7110 MK III-C, a particular model of breathalyzer, asserting that errors in the Alcotest’s source code as well as other deficiencies rendered the breath test results produced by the Alcotest unreliable. The judge denied the motion to exclude the breathalyzer evidence. The Supreme Judicial Court vacated the judge’s order, holding (1) breath test evidence is scientific evidence, and therefore, the reliability of the Alcotest breath test result had to be established before evidence of the test could be admitted, and, in the instant case, a hearing on Defendant’s challenges to that reliability were required; and (2) because no such hearing was held in this case and the Alcotest breath test result was before the jury as evidence, the case must be remanded to the district court for a hearing on Defendant’s motion to exclude. View "Commonwealth v. Camblin" on Justia Law

Defendant was charged with operating a vehicle while under the influence of liquor (OUI), third offense, resisting arrest, reckless operation of a motor vehicle, failure to stop for police, and a marked lanes violation. Defendant filed a motion to suppress, arguing that the arresting officer who pursued Defendant to Defendant’s garage, made an unconstitutional search and seizure by entering his garage. The motion judge denied the motion based on the existence of probable cause and several exigent circumstances, including hot pursuit. After a trial, the jury found Defendant guilty of all counts with the exception of reckless operation of a motor vehicle. The Supreme Court affirmed, holding (1) the arresting officer’s actions in entering Defendant’s garage to effectuate the arrest were lawful; and (2) the evidence was sufficient to establish the underlying OUI charge as well as Defendant’s two prior convictions. View "Commonwealth v. Jewett" on Justia Law

Defendant was convicted of murder in the first degree on theories of extreme atrocity or cruelty, felony murder, and armed robbery. The Supreme Judicial Court affirmed the convictions, holding (1) the trial judge did not err in denying Defendant’s motion to suppress evidence of his sneakers and evidence derived from blood found on his sneakers; (2) the trial judge did not err in instructing the jury on the theory of joint venture liability, over defense counsel’s objection; (3) the trial judge did not err in denying Defendant’s request for an instruction on involuntary manslaughter; and (4) the prosecutor did not improperly shift the burden of proof in her closing argument. View "Commonwealth v. Silva" on Justia Law

Defendant, a police officer, was charged with assault and battery by means of a dangerous weapon and assault and battery for beating an unarmed civilian after responding to another officer’s request for assistance with a traffic stop. After a jury trial, Defendant was found guilty of both charges. The Supreme Judicial Court affirmed, holding (1) the trial judge’s jury instructions were erroneous in that (i) they failed to acknowledge that Defendant was a police officer and that he was entitled to use force in carrying out his official duties if necessary and reasonable, and (ii) the self-defense instructions included an erroneous statement that Defendant had a duty to retreat if possible under the circumstances; and (2) the errors were not prejudicial. View "Commonwealth v. Asher" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree, assault with intent to kill, and assault and battery by means of a dangerous weapon. Defendant appealed, assigning error to several evidentiary rulings made by the trial judge. The Supreme Judicial Court affirmed Defendant’s convictions, holding (1) to the extent the trial judge erred in failing to instruct the jurors that they could consider Defendant’s custodial statements as evidence of consciousness of guilt if the Commonwealth proved that the statements were false, the error did not influence the jury; (2) the trial judge did not err in admitting a witness’s statement made on a 911 call; (3) the trial judge was within her discretion in excluding third-party culprit evidence; (4) the trial judge properly excluded certain evidence of the police investigation; and (5) the trial judge did not err in denying Defendant access to the treatment records of a Commonwealth witness or in limiting cross-examination of that witness. View "Commonwealth v. Alcantara" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on the theory of deliberate premeditation. Defendant was sixteen years old at the time of the murder. Defendant subsequently filed a motion to reduce the verdict to murder in the second degree. The trial judge granted the motion. After Defendant was resentenced, he filed a notice of appeal. Defendant then filed a motion for a new trial arguing that his Sixth Amendment right to a public trial was violated when the courtroom was closed during jury empanelment. The motion was denied, and Defendant appealed. The Supreme Judicial Court affirmed, holding that the lower court (1) did not err in reducing the verdict to murder in the second degree based on the facts of this case; and (2) did not err in failing to instruct the jury on involuntary manslaughter based on Defendant’s mental impairment of ADHD and depression in an adolescent brain. View "Commonwealth v. Pagan" on Justia Law

Defendant, a juvenile, was indicted as a youthful offender for possession of heroin with intent to distribute. Under the youthful offender statute, a juvenile may be prosecuted as an adult if the charge involves the “infliction or threat of serious bodily harm.” Defendant moved to dismiss the indictment, arguing that the Commonwealth presented insufficient evidence to the grand jury to establish this requirement where his offense was the mere possession of heroin with intent to distribute. The juvenile court denied the petition. The Supreme Judicial Court disagreed and reversed the decision of the single justice denying Defendant’s Mass. Gen. Laws ch. 211, 3 petition, holding that evidence of the generalized potential for harm from the sale or use of heroin, without more, does not meet the probable cause standard for “infliction or threat of serious bodily harm.” View "Felix F. v. Commonwealth" on Justia Law

Petitioner was charged with unarmed robbery and assault and battery. Notices were sent to Petitioner from three different courts alleging that Petitioner had violated the terms of his probation by committing the new offenses. The Boston Municipal Court judge found “no violation of probation” with respect to the new offenses. Petitioner then filed a motion in the New Bedford District Court and the Fall River District Court to hold the Commonwealth bound by the order of the Boston Municipal Court. Petitioner’s motion was denied. Thereafter, Petitioner filed a petition for relief in the county court pursuant to Mass. Gen. Laws ch. 211, 3, alleging that because the Boston Municipal Court had issued a final judgment deciding that he had not violated the terms of his probation by committing the new offenses, collateral estoppel barred a subsequent probation revocation proceeding in a different county on the new offenses. A single justice reserved and reported the case to the full court. The Supreme Judicial Court allowed the petition for relief, holding that principles of collateral estopped barred the Commonwealth from relitigating the same factual issue of whether Petitioner violated the terms of his probation with respect to the new offenses at subsequent probation revocation proceedings. View "Kimbroughtillery v. Commonwealth" on Justia Law