Justia Massachusetts Supreme Court Opinion Summaries

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

Defendant was on trial on indictments charging murder in the first degree and various firearm offenses. Before trial, the Commonwealth filed a motion in limine seeking to establish the admissibility of testimony from a certain witness as to conversations the witness had with Defendant. After the trial began, the trial judge denied the motion. The Commonwealth sought relief from a single justice of the Supreme Judicial Court pursuant to Mass. Gen. Laws ch. 211, 3. The single justice denied the petition. The Supreme Judicial Court affirmed, holding that the Commonwealth failed to demonstrate that the single justice committed a clear error of law or abused his discretion when he denied the Commonwealth’s petition. View "Commonwealth v. Hernandez" on Justia Law

Defendant was a participant in a drive-by shooting against a group of young men that killed one member of the group and wounded two others. The Supreme Judicial Court affirmed the convictions and declined Defendant’s request that it grant relief under Mass. Gen. Laws ch. 278, 33E, holding (1) the trial court did not err in admitting the grand jury of a Commonwealth witness; (2) the trial court did not err in admitting prior bad act evidence; (3) the trial court did not err in admitting evidence of Defendant’s refusal to have his custodial interrogation recorded; (4) the trial court did not err in admitting evidence of 911 calls received by a police dispatcher; (5) the trial court erred in admitting evidence concerning the course of the investigation and the role of the grand jury, but the error did not prejudice Defendant; (6) the prosecutor’s impeachment of a defense witness with her failure to report exculpatory evidence to police was not in error; (7) the prosecutor did not engage in impermissible misconduct during closing argument; and (8) the trial judge did not err in declining to give a Bowden instruction. View "Commonwealth v. DaSilva" on Justia Law

Defendants were convicted of possession of heroin and possession of firearms and ammunition. Defendants appealed, arguing, inter alia, that there was insufficient evidence to support their convictions. The Supreme Judicial Court affirmed in part and reversed in part, holding (1) the Commonwealth presented sufficient evidence to support Defendants’ convictions of possession of heroin; but (2) the Commonwealth did not present sufficient evidence to support a conclusion beyond a reasonable doubt that Defendants constructively possessed the firearms and ammunition found in the apartment in which they were staying. View "Commonwealth v. Dagraca-Teixeira" on Justia Law

Steven Fitzgerald pleaded guilty to certain criminal offenses. Fitzgerald subsequently filed a petition for relief under Mass. Gen. Laws ch. 211, 3 seeking to vacate his pleas, arguing that he was forcibly medicated when he tendered his pleas and that he has not been able to obtain a copy of a court file of an earlier proceeding which resulted in an order that he be involuntarily committed and treated with antipsychotic medications before he pleaded guilty. A single justice of the Supreme Judicial Court denied extraordinary relief. The Supreme Judicial Court affirmed, holding that Fitzgerald was not entitled to extraordinary relief under the circumstances of this case. View "Fitzgerald v. Dist. Court Dep’t of the Trial Court" on Justia Law

In 2011, Defendant was indicted on a charge of violating Mass. Gen. Laws ch. 94C, 32E(b)(2) for trafficking in cocaine with a total weight of 28.14 grams. In 2012, St. 2012, ch. 192 (Crime Bill) was enacted, which amended section 32E(b)(2), along with section 32E(b)(1), to redefine the minimum and maximum trafficking weights. The Crime Bill also reduced the mandatory minimum sentence required for a violation of both section 32(e)(b)(1) and (2). Prior to trial, Defendant filed a motion to apply all the Crime Bill’s amendments to section 32E(b)(1) and (2) to his case. The judge allowed Defendant’s motion. The Supreme Judicial Court affirmed in part and reversed in part, holding that, in accordance with Commonwealth v. Galvin, (1) the Crime Bill’s reduction of the mandatory minimum sentence required for a violation of section 32(b)(2) applies retroactively to Defendant; but (2) the reconfigured drug trafficking weights provided in sections 32E(b)(1) and (2), as amended by the the Crime Bill, do not apply retroactively to Defendant. Remanded. View "Commonwealth v. Didas" on Justia Law

Defendant was indicted for murder. Defendant moved to suppress certain evidence that the Commonwealth had obtained without a warrant. The superior court allowed Defendant’s motion. The Commonwealth appealed. The Supreme Judicial Court held that Defendant had a reasonable expectation of privacy in the evidence and remanded to give the Commonwealth an opportunity to demonstrate probable cause for a warrant. Defendant subsequently filed a Mass. R. Crim. P. 15(d) motion seeking attorney’s fees for counsel he engaged to replace his court-appointed counsel for the defense of the Commonwealth’s interlocutory appeal. The Supreme Court denied Defendant’s motion for appellate attorney’s fees, holding that Defendant was not entitled to the payment of fees where he was indigent and his new counsel agreed not to charge him any fees for their services. View "Commonwealth v. Augustine" on Justia Law

After a jury trial, Defendant was convicted of assault and battery by means of a dangerous weapon and assault and battery. Defendant appealed, arguing that the motion judge erred in denying a motion to suppress the victim’s out-of-court eyewitness identification, and (2) DNA evidence identifying the victim as the source of blood found on Defendant’s shirt should have been suppressed because the DNA analysis constituted a search that required a warrant. The Supreme Court affirmed, holding (1) although the victim had told the police that the assailant wore a gray shirt and Defendant was the only person shown wearing a gray shirt in the photographic array, the victim did not select the photograph on that basis, and therefore, the judge did not err in denying Defendant’s motion to suppress; and (2) where, as in this case, DNA analysis is limited to the creation of a DNA profile from lawfully seized evidence of a crime and the profile is used only to identify its unknown source, the DNA analysis is not a search within the meaning of the Fourth Amendment, and therefore, no search warrant was required to conduct the DNA analysis of the bloodstain from Defendant’s clothing in this case. View "Commonwealth v. Arzola" on Justia Law

In 2007, Defendant pleaded guilty to certain offenses in the superior court in Norfolk County. In 2008, Defendant pleaded guilty to a charge of unarmed robbery in the superior court in Plymouth County. Defendant was sentenced to a term of imprisonment, concurrent with the sentence in the Norfolk County case, which he was then serving. In 2013, Defendant moved to correct the mittimus as to the Plymouth County case, requesting credit for the time he was detained while awaiting trial. The superior court denied the motion on the ground that the time at issue had already been credited against Defendant’s sentence in the Norfolk County case and that Defendant had benefited from the concurrent sentences. The Supreme Judicial Court affirmed, holding that, under the circumstances, the motion judge was not obligated to grant Defendant’s request. View "Commonwealth v. Ridge" on Justia Law