Justia Massachusetts Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of murder in the first degree, the unlawful possession of a firearm, and the unlawful possession of ammunition. Defendant was sentenced to a mandatory sentence of life imprisonment for the murder conviction. Defendant’s motion for a new trial was denied. Defendant appealed, arguing, among other claims, that the trial judge erred in denying his request to instruct the jury on duress. The Supreme Judicial Court affirmed the convictions, holding (1) juveniles, along with adults, are generally barred from using a duress defense for intentional murder; (2) Defendant procedurally waived his Sixth Amendment right to a public trial during the jury empanelment, and therefore, his right to a public trial was not violated when the courtroom was closed for a period of sixty to ninety minutes during jury empanelment; and (3) Defendant was not prejudiced by a noncitizen juror deciding his case. View "Commonwealth v. Jackson" on Justia Law

After a jury trial, Defendant was found guilty of murder in the first degree, on theories of deliberate premeditation and felony-murder, and armed robbery. The motion judge dismissed the armed robbery conviction as duplicative. Defendant appealed, arguing that the motion judge erred in denying his motion to suppress evidence seized from his room in a “sober house” pursuant to a search warrant, alleging that there was no probable cause that he was the perpetrator. The Supreme Judicial Court affirmed the convictions and declined to reduce the verdict of murder to a lesser degree of guilt or to grant a new trial, holding (1) the motion judge did not err in denying Defendant’s motion to suppress, as there was probable cause to issue a search warrant; (2) because Defendant was convicted of murder on theories of both premeditation and felony murder and because the Court affirmed on both theories, the conviction of armed robbery was not duplicative and should not have been dismissed; and (3) there was no reason to reduce the verdict of murder in the first degree or to order a new trial. View "Commonwealth v. Foster" on Justia Law

After a jury trial, Defendant was found guilty of murder in the first degree on a theory of extreme atrocity or cruelty and possessing a firearm without a license. The Supreme Judicial Court affirmed the convictions, holding that the trial judge (1) did not err in denying Defendant’s motion to suppress statements he made to police following his arrest, as Defendant voluntarily waived his Miranda rights, and his statements were voluntary; and (2) did not deprive Defendant of a defense by declining to instruct the jury on the uncharged offense of accessory after the fact where the judge’s instructions clearly indicated that Defendant could not be convicted of murder if the jury concluded that Defendant’s role was indeed limited to aiding in the shooter’s escape from the police. View "Commonwealth v. Newson" on Justia Law

After a jury-waived trial, Defendant was convicted of trafficking in heroin and cocaine and of unlawful possession of marijuana with intent to distribute. Defendant appealed the denial of his motion to suppress evidence obtained from his apartment by police officers during the execution of an “anticipatory search warrant,” claiming that the officers had executed the search before the “triggering events” stated in the affidavit had occurred. The Supreme Judicial Court affirmed the denial of the motion to suppress and the resulting convictions, holding (1) where, as in this case, the Commonwealth applies for an anticipatory search warrant and the judicial authorization to execute the search is conditioned on the occurrence of a specific future event, the search is authorized by the warrant where there is equivalent compliance with that condition precedent; and (2) in this case, there was both equivalent compliance with the warrant’s triggering conditions, and compliance with those conditions provided probable cause to search Defendant’s residence. View "Commonwealth v. Colondres" on Justia Law

After a jury trial, Defendant was found guilty of murder in the first degree and assault and battery by means of a dangerous weapon on a person sixty years of age or older. The Supreme Judicial Court affirmed Defendant’s convictions, holding (1) the trial court did not err by not explicitly instructing the jury that when considering whether to accept Defendant’s statements to law enforcement under the human practice rule, they were entitled to evaluate the validity of his Miranda waiver as a factor; (2) the judge’s instructions regarding Defendant’s defense of mental impairment did not give rise to a substantial likelihood of a miscarriage of justice; (3) Defendant’s convictions and sentences were not duplicative; and (4) the trial judge’s action of designating a sleeping juror as an alternate did not amount to a substantial likelihood of a miscarriage of justice. View "Commonwealth v. The Ngoc Tran" on Justia Law

Defendant was convicted of murder in the second degree for the shooting of a fourteen-year-old. Defendant was seventeen years and five months old at the time of his arrest for the shooting. Defendant appealed the district court’s denial of his motion to suppress incriminating statements that he made to the police after waiving his Miranda rights, arguing that their introduction at trial was error given the common-law rule that, ordinarily, a juvenile must be given a meaningful opportunity to consult with an interested adult before waiving his Miranda rights, an opportunity he did not have. Several years after Defendant was convicted, the Legislature enacted St. 2013, ch. 2013 (2013 act), which amended various statutory provisions to treat seventeen year olds as juveniles. The Supreme Judicial Court affirmed Defendant’s conviction, holding (1) the 2013 act did not affect this case because it is prospective in its application and does not modify the interested adult rule; but (2) the interest adult rule is now extended, on a prospective basis, to seventeen year old defendants. View "Commonwealth v. Smith" on Justia Law

After a jury trial, Defendant was convicted on two indictments charging indecent assault and battery on a child under fourteen, in violation of Mass. Gen. Laws ch. 265, 13B, and one indictment charging dissemination of matter harmful to minors, in violation of Mass. Gen. Laws ch. 272, 28. The Supreme Judicial Court affirmed the convictions, holding (1) during the time period alleged in the indictment, section 28 was not unconstitutionally over broad because, contrary to Defendant's assertions, the statute implicitly required a defendant’s knowledge that the person receiving the harmful matter was a minor; and (2) the prosecutor’s suggestion that the defendant would have committed further sexual offenses against one of the child victims had the child not moved away was improper but, in the context of the entire closing argument, did not create a substantial risk of a miscarriage of justice. View "Commonwealth v. Jones" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on the theory of felony-murder, unlawful possession of a firearm, and unlawful possession of a loaded firearm. The Supreme Judicial Court affirmed, holding (1) the trial court did not err in denying Defendant’s motion to suppress a letter he wrote to another detainee while he was detained awaiting trial; (2) the trial court did not err by not instructing, sua sponte, on involuntary manslaughter based on wanton or reckless conduct; and (3) Defendant’s trial court was ineffective in not requesting an instruction on involuntary manslaughter based on wanton or reckless conduct. View "Commonwealth v. Jessup" on Justia Law

Defendant pleaded guilty to trafficking in cocaine and unlawful possession of ammunition. Two years later, Sonja Farak, a chemist at the Department of Public Health’s State Laboratory Institute in Amherst during the time of Defendant’s criminal case, was indicted on numerous counts of tampering with evidence, theft of a controlled substance from a dispensary, and unlawful possession of a class B substance. Three weeks later, Defendant filed a motion to withdraw his guilty pleas pursuant to Mass. R. Crim. P. 30(b), alleging that Farak’s misconduct cast serious doubt on the justice of his convictions. A superior court judge denied Defendant’s motion. Farak subsequently pleaded guilty to all charges. The Supreme Judicial Court vacated the order denying Defendant’s motion to withdraw his guilty pleas, holding that, due to the Commonwealth’s failure to thoroughly investigate Farak’s misconduct at the Amherst drug lab, Defendant was entitled to a measure of relief. Remanded. View "Commonwealth v. Cotto" on Justia Law

Between 2004 and 2013, Defendant was indicted on drug charges in three separate cases. Also during that time, Sonja Farak was a chemist at the Department of Public Health’s State Laboratory Institute in Amherst. Farak later pleaded guilty to several counts of tampering with evidence, theft of a controlled substance from a dispensary, and unlawful possession of cocaine. Based on Farak's misconduct, Defendant filed a motion pursuant to Mass. R. Crim. P. 30(c)(4) for leave to conduct postconviction discovery and for funds with respect to the three cases that had been brought against him. Defendant sought retesting of drug evidence maintained by the Springfield police department that related to the cases brought by the Commonwealth between 2004 and 2013. The superior court judge denied Defendant’s motion for leave to conduct postconviction discovery, concluding that Defendant failed to establish a prima facie case for relief under Rule 30(c)(4). The Supreme Judicial Court affirmed the order but remanded for further proceedings, holding that Defendant was entitled to retest the controlled substance that gave rise to his 2009 indictment charging distribution of cocaine as a subsequent offense. View "Commonwealth v. Ware" on Justia Law