Justia Massachusetts Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of one count of assault and battery against his sister. During trial, Defendant’s principal contention was that his sister and her boyfriend fabricated their allegations against him in order to justify the boyfriend’s actions of attacking Defendant and accidentally injuring the sister in the process. The Supreme Court reversed and remanded for a new trial, holding that the trial judge abused his discretion in refusing to allow Defendant to pursue his theory through extrinsic evidence and examination of the two witnesses because, if the evidence was credited by the jury, it would have supported an inference of bias, prejudice, and motive to prevaricate. View "Commonwealth v. Magdalenski" on Justia Law

Petitioners were three individuals who pleaded guilty to various drug offenses in cases where Annie Dookhan, a chemist employed in the forensic drug laboratory of the William A. Hinton State Laboratory Institute who committed egregious misconduct, signed the certificates of drug analysis. Petitioners filed a petition pursuant to Mass. Gen. Laws ch. 211, 3 asking that if they exercise their right to postconviction relief they should not receive harsher punishment. The Committee for Public Counsel Services (CPCS) moved to intervene, arguing that the Court should implement a “global remedy” to resolve the myriad cases affected by Dookhan’s egregious misconduct. The Supreme Judicial Court granted the motion to intervene and granted relief in part, holding, primarily, (1) a defendant who has been granted a new trial based on Dookhan’s misconduct cannot be charged with a more serious offense than that of which he or she was initially convicted and, if convicted again, cannot be given a more severe sentence than that which was originally imposed; and (2) a so-called “global remedy” will not be implemented at this time. The remainder of the Court’s holdings concerned evidentiary rules to be followed in the event a “Dookhan defendant” pursues a motion to withdraw a guilty plea. View "Bridgeman v. Dist. Attorney for Suffolk Dist." on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree based on deliberate premeditation. Defendant was convicted on a theory of joint venture with the shooter, who took the gun from Defendant’s hand and began shooting. The Supreme Judicial Court vacated Defendant’s conviction on the murder charges and remanded for a new trial on those indictments, holding that the judge erred in misstating the law of joint venture in her response to a jury question, and the error created a substantial likelihood of a miscarriage of justice because the response to the jury’s question obscured or eliminated the possibility that Defendant could be convicted of any lesser offense. View "Commonwealth v. Tavares" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree. Defendant filed a direct appeal and also appealed the denial of his motion for a new trial. The Supreme Judicial Court affirmed the conviction and the order denying Defendant’s motion for a new trial and declined to exercise its power under Mass. Gen. Laws ch. 278, 33E, holding (1) the judge considering Defendant’s motion for a new trial did not abuse its discretion in denying the motion without an evidentiary hearing; (2) assuming, without deciding, that the Commonwealth failed to timely disclose exculpatory evidence, the nondisclosure did not result in a substantial likelihood of a miscarriage of justice; (3) the prosecutor did not commit prosecutorial misconduct; and (4) Defendant’s trial counsel did not provide ineffective assistance. View "Commonwealth v. Vaughn" on Justia Law

At Defendant’s trial for murder and conspiracy, the prosecution’s theory was that Defendant had hired an assassin to kill the victim. Defendant testified on his own behalf, refuting the allegations. After the jury was charged, it was discovered that Defendant had suffered a stroke that had occurred on the night between the first and second days of his testimony. The jury never learned of Defendant’s stroke and returned guilty verdicts on both indictments. The trial judge ordered a new trial, determining that Defendant’s then-undetected stroke might have so affected the course of his testimony as to damage his credibility in the jury’s eyes, and given the importance of the jury’s assessments of credibility in this case, justice may not have been done. The Supreme Judicial Court affirmed, holding that, in the highly unusual circumstances presented here, there was no abuse his discretion in the judge’s decision that “justice may not have been done.” View "Commonwealth v. Brescia" on Justia Law

After a jury trial, Defendant was convicted of killing his wife with deliberate premeditation. The Supreme Judicial Court affirmed the conviction and declined to exercise its powers under Mass. Gen. Laws ch. 278, 33E, holding that the trial court did not err in (1) admitting two postmortem photographs depicting the victim’s body; (2) failing to grant a mistrial after the medical examiner testified that the victim’s death was a homicide, when the defense was that it was a suicide, where the judge promptly struck the improper testimony and gave a highly specific curative instruction; (3) admitting Defendant’s statements to police with no redactions; and (4) failing to conduct a voir dire of jurors after at least one juror had been exposed to prejudicial extraneous material. View "Commonwealth v. Amran" on Justia Law

Petitioner was convicted of two counts of assault and battery on a police officer, resisting arrest, disturbing the peace, and disorderly conduct. More than twenty months after he was sentenced, Petitioner filed a motion with the Appellate Division of the superior court requesting that the Appellate Division accept an appeal of his sentences to the house of correction. See Mass. Gen. Laws ch. 278, 28A-28C. The motion was denied. Petitioner then filed a petition pursuant to Mass. Gen. Laws ch. 211, 3. A single justice of the Supreme Judicial Court denied relief. The Supreme Judicial Court affirmed, holding that the challenged sentences were not within the jurisdiction of the Appellate Division because the sentence was not a felony sentence to the State prison. View "Starks v. Commonwealth" on Justia Law

David Forlizzi and Fred Battista (together, Petitioners) were indicted on similar charges arising out of Petitioners’ alleged misconduct in connection with a prior trial involving alleged insurance fraud. Petitioners moved to dismiss the indictments, alleging that the Commonwealth had engaged in prosecutorial misconduct during the investigation leading to the indictments. A superior court judge denied the motion, concluding that the prosecutors had engaged in overreaching but that dismissal of the indictments as a sanction was not warranted under the circumstances. Petitioners filed a petition in the county court pursuant to Mass. Gen. Laws ch. 211, 3 seeking interlocutory review. A single justice of the Supreme Judicial Court denied relief, concluding that Petitioners had not shown they were entitled to extraordinary relief. The Supreme Judicial Court affirmed the denial of the petition on the ground that Petitioners failed to demonstrate irremediable error. View "Forlizzi v. Commonwealth" on Justia Law

In November 2012, voters approved the Commonwealth’s new medical marijuana law. In May 2013, Defendant was charged with possession with the intent to distribute marijuana, distribution of marijuana, and conspiracy to violate the drug laws. The charges arose from a search of Defendant’s property pursuant to a search warrant issued in May 2013. Defendant filed a motion to suppress the evidence obtained pursuant to the warrant. The district court allowed Defendant’s motion, concluding that the affidavit filed in support of the search warrant application demonstrated probable cause that Defendant was cultivating marijuana at the property but, in light of the act, failed to establish probable cause that Defendant was not authorized to do so and therefore was committing a crime. The Supreme Judicial Court affirmed, holding that the affidavit failed to establish probable cause for the search. View "Commonwealth v. Canning" on Justia Law

After a jury-waived trial, Plaintiff was found guilty of malicious destruction of property, breaking and entering in daytime, and larceny over $250. The Appeals Court reversed Plaintiff’s convictions, concluding that the Commonwealth’s evidence was insufficient to support the convictions. Thereafter, Plaintiff filed a complaint under Mass. Gen. Laws ch. 258D, the erroneous convictions statute, seeking compensation for his erroneous convictions. The Commonwealth filed a motion to dismiss Plaintiff’s complaint, arguing that Plaintiff did not meet his threshold burden of proving that his convictions were overturned “on grounds which tend to establish [his] innocence” under the erroneous convictions statute. A judge denied the motion. The Commonwealth appealed. The Supreme Judicial Court affirmed the denial of the motion to dismiss, holding that the reversal of Plaintiff’s convictions due to insufficient evidence amounted to grounds which tend to establish Plaintiff’s innocence, thus rendering Plaintiff eligible to obtain relief under the erroneous convictions statute. View "Renaud v. Commonwealth" on Justia Law