Justia Massachusetts Supreme Court Opinion Summaries

Defendants were indicted on charges of murder, among other charges. The jury foreman initially announced not guilty verdicts as to each of the murder indictments but later amended the previously announced not guilty verdicts to find Defendants guilty of murder in the first degree. The Supreme Judicial Court reversed the convictions for reasons not relevant to this appeal and remanded for a new trial. Defendants were retried and again convicted. The Supreme Court affirmed. Following various proceedings, Defendants filed a third motion for a new trial arguing that the jury had actually acquitted them of murder in the first degree on a theory of deliberate premeditation in the first trial, and therefore, the retrial on that same theory in the second trial violated their double jeopardy rights. A superior court judge denied the motion. The Supreme Judicial Court affirmed, holding that the jury’s initial verdict did not have the double jeopardy consequence of barring retrial on a theory of premeditated murder. View "Commonwealth v. Brown" on Justia Law

Defendant was stopped and arrested by law enforcement officers at the same time and in the same location as another man, Edwin Ramos, from whose person the officers recovered a packet of cocaine. Ramos was charged with possession of cocaine, and Defendant was charged with unlawful distribution of that same cocaine. A superior court judge allowed Defendant’s motion to suppress, concluding that Defendant was entitled to assert standing to challenge the search and seizure of cocaine from Ramos under a theory of “target standing.” The Supreme Judicial Court reversed, holding that the facts of this case did not support Defendant’s claim of target standing. Remanded. View "Commonwealth v. Santiago" on Justia Law

Plaintiff was convicted by general court martial of three specifications in violation of art. 134, 10 U.S.C. 934, the “general” provision of the Uniform Code of Military Justice. Plaintiff pleaded guilty to the article 134 charge and to each of the underlying specifications. After Plaintiff was released from confinement, the Sex Offender Registry Board notified him of his duty to register as a level two sex offender. Following Plaintiff’s appeal, the board upheld the classification, determining that the specifications underlying Plaintiff’s conviction were each a “like violation” to sex offenses under Mass. Gen. Laws ch. 6, 178C. The Board later successfully sought reclassification of Plaintiff as a level three sex offender. Plaintiff appealed that decision. The superior court reversed, determining that the Board lacked jurisdiction over Plaintiff because his conviction under article 134 was not a “like violation” to a Massachusetts sex offense. The Supreme Judicial Court vacated the judgment of the superior court, holding that article 134, although general in scope, assimilates the elements of underlying offenses, and, under the circumstances of this case, the article 134 conviction was a sex offense under chapter 6, section 178C. View "Doe v. Sex Offender Registry Bd." on Justia Law

A Newspaper sought postverdict access to the list containing the names and addresses of the jurors who served at the criminal trial of a defendant on charges of murder in the first degree and assault and battery. The trial judge ruled that he would ask jury members if they were amenable to speaking to the press and would permit disclosure only as to those jurors who responded affirmatively. The Newspaper filed a petition for relief from the judge’s ruling. The Supreme Judicial Court set aside the trial judge’s order in part and instructed that a list identifying the names of the jurors, without addresses, be disclosed, holding (1) the public’s long-term interest in maintaining an open judicial process requires that a list identifying the names of jurors who have been empanelled and rendered a verdict in a criminal case be retained in the court file of the case and be made available to the public; and (2) only on a judicial finding of good cause may such a list be withheld. View "Commonwealth v. Fujita" on Justia Law

Defendant was acquitted on eighteen counts of statutory rape but convicted on seven counts of the lesser-included offense of indecent assault and battery on a child under the age of fourteen. On appeal, Defendant argued, among other things, that the trial judge’s instruction on reasonable doubt was constitutionally inadequate, and even if it was constitutionally sound, the charge on reasonable doubt established more than 150 years ago in Commonwealth v. Webster should be required in all criminal trials. The Supreme Judicial Court affirmed the convictions, holding (1) pursuant to the Court’s general superintendence power, a modernized version of the Webster charge must be given in criminal trials on a prospective basis; and (2) Defendant was not entitled to a special retroactive application of this new rule, and the judge’s instruction on reasonable doubt in this case passed constitutional muster. View "Commonwealth v. Russell" on Justia Law

Defendant was indicted on charges of murder, armed assault with intent to murder, accessory after the fact to murder, and unlawful possession of firearms. After a jury trial, Defendant was found guilty of accessory after the fact and unlawful possession of firearms. Because the jury could not reach a verdict on the indictments charging murder and armed assault with intent to murder, the judge declared a mistrial as to those indictments. The Commonwealth subsequently requested that sentencing on the indictments on which Defendant was found guilty be postponed until he could be retried on the indictments that were mistried. Defendant moved to dismiss the mistried indictments, arguing, inter alia, that the trial court erred by not allowing his motion for required findings of not guilty as to the mistried indictments. The Supreme Judicial Court agreed with Defendant and reversed the denial of the motion for required findings of not guilty as to the mistried indictments and directed entry of verdicts of not guilty as to those indictments because the Commonwealth did not satisfy its burden of proof. Remanded for sentencing. View "Commonwealth v. Simpkins" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on the theories of deliberate premeditation and felony-murder, among other crimes. The Supreme Judicial Court affirmed the convictions and declined to grant relief under Mass. Gen. Laws ch. 278, 33E, holding (1) the trial judge did not abuse her discretion by restricting Defendant’s attendance at a jury view; (2) the trial judge did not err by admitting a witness’s testimony that the witness saw Defendant with a gun more than one year before the shooting in question occurred; (3) the police’s failure to examine the money seized from Defendant’s residence for fingerprints of DNA before depositing the money into a bank account did not warrant dismissal of the charges against him; and (4) the trial judge’s exclusion of video and testimony of Defendant’s expert showing that surveillance footage of the shooting distorted the height of the perpetrator did not infringe on Defendant’s right to present a defense. View "Commonwealth v. Corliss" on Justia Law

Defendant was indicted on charges of murder in the first degree under theories of premeditation and extreme atrocity or cruelty. Defendant moved to suppress the eyewitness identifications of him as the shooter and the identifications of his jacket, which had been found in the path of flight and identified by two witnesses as the one worn by the shooter. The motions were denied. Defendant was subsequently convicted of murder in the first degree on a theory of deliberate premeditation and sentenced to life in prison without the possibility of parole. The Supreme Judicial Court affirmed the conviction, holding (1) the admission of the jacket identifications did not violate due process or Mass. R. Crim. P. 14 where the Commonwealth did not arrange a “jacket lineup”; (2) no reversible error arose from Defendant’s other claims; and (3) although evidence of questionable conduct by some of the investigating police officers was brought out during the course of the proceedings, there was an insufficient basis for the Court to exercise its authority under Mass. Gen. Laws ch. 278, 33E to order a new trial or reduce the degree of guilt. View "Commonwealth v. Bresilla" on Justia Law

The Commonwealth moved for judicial approval of a grand jury subpoena compelling a law firm representing John Doe, who was the target of a grand jury investigation, to produce a telephone Doe transferred to the law firm in connection with its provision of legal services to him. The Commonwealth asserted that the telephone was transferred from Doe to the law firm to obtain legal advice and that it contained evidence, particularly in its record of text messages, of the crime under investigation by the grand jury. A single justice of the Supreme Judicial Court approved the issuance of the subpoena on the basis that the Commonwealth had, through an ex parte proceeding, established probable cause sufficient to justify a search under the Fourth Amendment. The Supreme Judicial Court reversed, holding that the attorney-client privilege protected Doe against compelled production of the telephone by the law firm and that the privilege may not be set aside based on a showing of probable cause. View "In re a Grand Jury Investigation" on Justia Law

After a retrial before a jury, Defendant was convicted of assault by means of a dangerous weapon and other offenses. Before trial, two eyewitnesses described Defendant’s gender and race and the color of his clothing. However, neither eyewitness identified Defendant at the live lineup. The trial judge refused to give a modified identification instruction providing that the jury may consider that the eyewitnesses had the opportunity to view Defendant but did not identify him. The Supreme Judicial Court affirmed, holding that the judge did not abuse his discretion by declining to give an identification instruction where there was no positive eyewitness identification and no other eyewitness testimony that significantly incriminated Defendant. View "Commonwealth v. Johnson" on Justia Law