Justia Massachusetts Supreme Court Opinion Summaries

After a jury trial, Appellant was convicted of murder in the first degree. The Supreme Judicial Court affirmed the conviction. Appellant later filed a motion for a new trial, alleging that his trial counsel provided ineffective assistance by failing to impeach a witness as to one of his statements and that he was deprived of counsel when his trial counsel’s law partner stood in during jury deliberations. The motion was denied without a hearing. The Supreme Judicial Court affirmed, holding (1) trial counsel did not render ineffective assistance in failing to impeach a witness as to one of his statements or in allowing her partner to stand in for her during jury deliberations; and (2) any error in permitting substitute counsel to stand in for trial counsel was not structural warranting a new trial absent a showing of prejudice. View "Commonwealth v. Valentin" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on a theory of deliberate premeditation. On appeal, Defendant conceded that the evidence was sufficient to support the jury’s verdict and did not argue that any error occurred at trial. Rather, Defendant argued that the verdict was against the weight of the evidence where considerable evidence suggested that he acted in self-defense and also pointed to mitigation based on heat of passion. The Supreme Court affirmed, holding that Defendant’s trial was conducted fairly and without error, and there was no reason to reduce Defendant’s conviction to a lesser degree of guilt or to order a new trial. View "Commonwealth v. Ortiz" on Justia Law

Defendant, who was in the business of collecting and selling scrap metal, was convicted of larceny under $250 in connection with his removal of steel pipe from a construction site located on private property. Defendant claimed as an affirmative defense at trial that he lacked the requisite intent to steal because he honestly but mistakenly believed that the property he removed from the site was abandoned. The trial judge viewed the affirmative defense as requiring proof that Defendant’s belief was objectively reasonable. The Supreme Judicial Court vacated the conviction and remanded for a new trial, holding (1) an honest belief need not be objectively reasonable to negate the specific intent required for larceny; and (2) Defendant adequately raised the defense of honest belief that the items he took were abandoned, and it was the Commonwealth’s burden to prove beyond a reasonable doubt that Defendant’s subjective belief was not honestly held but, instead, was a pretense. View "Commonwealth v. Liebenow" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree. Defendant appealed, arguing that the trial court erred in denying his motion to suppress a surreptitiously recorded oral conversation between him and a police informant, that evidence of the conversation should have been excluded at trial, and therefore, that his conviction must be reversed. At issue before the Supreme Court was whether the one-party consent exception to the statutory prohibition against the secret recording or oral communications applied in this case. The Supreme Court reversed Defendant’s conviction, holding that the recorded conversation did not fit within the exception, that the conversation should not have been admitted in evidence at trial, and that the error was not harmless. View "Commonwealth v. Burgos" on Justia Law

Following a jury trial, Defendant was convicted of distributing cocaine and doing so in a school zone. Defendant appealed. While the appeal was pending, the school zone statute was amended to reduce the radius of the school zone. The appeals court affirmed Defendant’s convictions, concluding that the amendment did not have retroactive effect. The Supreme Judicial Court affirmed, holding that the Legislature did not intend to grant new trials to defendants who already had been convicted after the effective date of the amendment, and therefore, the amendment did not entitle Defendant to a new trial on his conviction of a school zone violation. View "Commonwealth v. Thompson" on Justia Law

John Doe, who was thirty-one years old, pleaded guilty to several sex offenses that he committed when he was a juvenile. Seven years later, Doe was classified as a level one sex offender. The classification was upheld by a judge of the superior court. Doe appealed, arguing that he should not be required to register as a sex offender in light of scientific research showing that adolescent brains are different from adult brains and in light of the long period of time that had elapsed since his last offense. The Supreme Court affirmed the superior court judge’s decision upholding the hearing examiner’s classification determination, holding that the hearing examiner’s decision was supported by substantial evidence. View "Doe v. Sex Offender Registry Bd." on Justia Law

After a jury trial, Defendant was convicted of deliberately premeditated murder and possession of a class B substance. The Supreme Judicial Court affirmed Defendant’s convictions, holding (1) there was no error in the denial of Defendant’s motion for a required finding of not guilty, as the evidence was sufficient to support a conviction of deliberately premeditated murder; (2) the trial court did not err in Defendant’s motion to dismiss based on Mass. R. Crim. P. 36, as amended, for the alleged denial of Defendant’s right to a speedy trial; (3) there was no error in the denial of Defendant’s motion to dismiss for belated discovery disclosure; (4) the trial judge did not err in failing to declare, sua sponte, a mistrial based on alleged jury tampering; and (5) there was no error in the judge’s instruction concerning the manner in which the jury should consider the testimony of a cooperating witness. View "Commonwealth v. Roman" on Justia Law

After a jury trial, Defendant was found guilty of six counts of possessing child pornography. Each count was premised on one or two distinct photographs culled at the same time from a single cache on Defendant’s computer. Defendant appealed, arguing that his convictions were duplicative. The Supreme Judicial Court vacated the convictions and remanded for a new trial, holding (1) where offending photographs come from a single cache and the defendant is charged with possessing them at the same point in time, the proper unit of prosecution for the possession of child pornography is only a single unit of prosecution; and (2) accordingly, the entry of six separate convictions and sentences constituted multiple punishments for the same offense in violation of the guaranty against double jeopardy. View "Commonwealth v. Rollins" on Justia Law

After a jury trial, Defendant was found guilty of murder in the first degree on theories of extreme atrocity or cruelty and felony-murder, based on the underlying felonies of home invasion and armed or assaultive burglary, and five related offenses. The jury did not specify whether they found Defendant guilty of the offenses as a principal or as a joint venturer. The Supreme Judicial Court affirmed, holding (1) the evidence was sufficient to establish that Defendant shared the intent required to support his convictions; (2) there was no abuse of discretion in the manner in which the judge limited the scope of the cross-examination and the redirect examination of one of the Commonwealth’s witnesses; (3) the trial judge did not err in denying Defendant’s request for an instruction on murder in the second degree based on an uncharged offense or an instruction on intervening cause; and (4) counsel was not ineffective for failing to object when the judge instructed that accident was not a defense to the killing. View "Commonwealth v. Garcia" on Justia Law

After a jury trial, Defendant was found guilty of murder in the first degree on theories of deliberate premeditation and extreme atrocity or cruelty. The Commonwealth’s theory at trial was that Defendant, who was in the midst of a contentious divorce from the victim, had engaged in a murder-for-hire scheme with Steven Stewart, who stabbed the victim, and their mutual friend, Richard Grebauski, the alleged middleman. The Supreme Judicial Court affirmed the conviction, holding (1) the trial court did not err in admitting a number of out-of-court statements introduced through Stewart’s testimony under the joint venture exception to the hearsay rule; (2) the trial court erred in admitting evidence that Defendant said he wanted his son killed and admitting testimony concerning a lumber theft by Stewart and Grebauski, but the errors did not result in a substantial likelihood of a miscarriage of justice; (3) the trial judge erred in deciding not to admit testimony concerning purportedly exculpatory statements made by Grebauski, but the error did not result in prejudice to Defendant; and (4) there was no prejudicial error in certain remarks made by the prosecutor during closing argument. View "Commonwealth v. Carriere" on Justia Law