Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court remanded this case to the county court for entry of a judgment reversing the order of the motion judge allowing Defendant's motion for discovery and requiring the Commonwealth to disclose information about a confidential informant, holding that the Commonwealth's invocation of the informant privilege was proper. In obtaining a search warrant that led to the seizure of firearms from Defendant's apartment and Defendant's ensuing arrest on firearms and ammunition charges, the Commonwealth relied on information from the informant at issue. After he was charged, Defendant filed a motion seeking discovery of offers made to the informant and documents related to the informant's participation in other criminal investigations. The motion judge allowed the motion. The Supreme Judicial Court reversed, holding that the motion judge abused her discretion in granting the motion because the requested information would effectively disclose the informant's identity and Defendant failed to show that the informant was relevant and material to her defense. View "Commonwealth v. Whitfield" on Justia Law

The Supreme Judicial Court vacated the order of the motion judgment dismissing indictments against Derrick Gentry-Mitchell and Joseph Sullivan, Springfield police department officers, charging them with misleading investigators, holding that the indictments did not violate article 12 of the Declaration of Rights of the Massachusetts Constitution.In dismissing the indictments charging misleading investigators, the motion judge, citing Commonwealth v. Barbosa, 421 Mass. 547 (1995), concluded that the indictments presented the possibility that Defendants might be convicted of a felony offense without first being indicted of the same by a grand jury because the indictments charged multiple acts in a single count. The Supreme Judicial Court reversed and remanded this case for further proceedings, holding (1) the indictments charged the essential crime of willfully misleading investigators to impeded the investigation of the same underlying event - the alleged assault of the victim by Defendants, who were off duty at the time; (2) the misleading statements constituted a continuing course of conduct actuated by a single, continuing impulse or intent, or general scheme to conceal that event; and (3) therefore, the indictments did not violate article 12. View "Commonwealth v. Sullivan" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of unlawful possession of a firearm, holding that the did not abuse its discretion in denying Defendant's motion for discovery, and there was no error in the proceedings below warranting a new trial.Defendant's conviction arose from a police investigation into a report of a shooting in a crowded residential area and the ensuing discovery of a firearm allegedly discarded by Defendant. Before trial, Defendant filed a motion for discovery of police reports that he argued was relevant and material to the question of whether the investigation was motivated by race, in violation of his constitutional equal protection rights. The trial judge denied the motion, and Defendant was subsequently convicted. The Supreme Judicial Court affirmed, holding (1) there was no abuse of discretion in the denial of Defendant's motion for discovery; and (2) some of the prosecutor's remarks during closing argument were improper, but the remarks did not warrant a new trial. View "Commonwealth v. Cuffee" on Justia Law

The Supreme Judicial Court affirmed the denial of Defendant's motion to suppress evidence seized from his person during a stop and pat-frisk, holding that the new standard adopted in Commonwealth v. Long, 485 Mass. 711, 724-725 (2020), is applicable in the context of police investigations such as pedestrian stops in addition motor vehicle stops.Defendant was indicted on firearm-related charges after he was stopped by police officers while walking. In his motion to suppress, Defendant argued that the stop was unconstitutional because the officers lacked reasonable suspicion and because statistical evidence proved the officers were more likely to stop Black members of the community than individuals of other races. In addressing Defendant's equal protection challenge, the lower court presumed that this Court's standard for establishing an equal protection claim under the Massachusetts Declaration of Rights, which was adopted to provide a defendant a more accessible path to pursuing an equal protection claim in the context of a motor vehicle stop, applied equally to this pedestrian stop challenge. The Supreme Judicial Court affirmed, holding (1) the new standard adopted in Long is applicable in this case; and (2) the evidence supported the trial court's determination that the officers stopped Defendant to investigate his involvement in the shooting and not because of his race. View "Commonwealth v. Robinson-Van Rader" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court convicting Defendant of murder in the first degree on a theory of extreme atrocity or cruelty and declined to grant relief under Mass. Gen. Laws ch. 278, 33E, holding that Defendant was not entitled to relief on his claims of error.On appeal, Defendant argued that his motions for a required finding should have been allowed because there was insufficient evidence to support a finding that he was the perpetrator. The Supreme Judicial Court disagreed, holding (1) the Commonwealth met its burden to prove that there was sufficient evidence for the jury to find, beyond a reasonable doubt, that Defendant had killed the victim; and (2) the trial judge did not abuse her discretion in allowing the introduction of certain evidence. View "Commonwealth v. MacCormack" on Justia Law

The Supreme Judicial Court held that a closed case that ends in an acquittal, a no bill from a grand jury, or a finding of no probable cause by the court is not a record subject to a presumption of access under the First Amendment and that the Legislature clearly abrogated the common-law presumption of access with respect to these records by its plain language in Mass. Gen. Laws ch. 276, 100C.Defendant was arraigned on two counts of rape while armed with a firearm and other crimes. A jury acquitted Defendant on one count of rape while armed, assault with intent to rape, and carrying a firearm without a license and deadlocked on the remaining three counts, resulting in a mistrial. The Commonwealth ultimately filed a nolle prosequi. Defendant later brought his section 100C petition to seal his criminal record as to the counts on which he was acquitted and the courts for which the nolle prosequi was filed. A judge denied the petition. The Supreme Judicial Court remanded the case for further proceedings, holding that, regarding the counts in which the nolle prosequi was entered, the judge abused his discretion when weighing the relevant interests and factors. View "Commonwealth v. J.F." on Justia Law

The Supreme Judicial Court reduced Defendant's convictions of armed robbery while masked to unarmed robbery and vacated the judgment on the conviction of armed home invasion and set aside the verdict, holding that an instructional error created a substantial risk of a miscarriage of justice.Defendant was convicted, after a jury trial, of armed home invasion and armed robbery while masked. While the indictments were based on a theory of joint venture the jury were not instructed that the Commonwealth must prove that Defendant knew that at least one coventurer was armed and at least one coventurer was armed and masked. The Supreme Court held (1) the failure to provide these instructions was error; and (2) the error left the Court with a serious doubt whether the result of the trial might have been different had the jury been correctly instructed. View "Commonwealth v. Desiderio" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of two counts of two counts of murder in the first degree on the theory of premeditation as to Mark Greenlaw and Jennifer O'Connor and on the theory of extreme atrocity or cruelty as to O'Connor, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Judicial Court held (1) the trial judge did not abuse his discretion in denying Defendant's motion for a mistrial regarding the victim's fear of rape; (2) the prosecutor's statement during closing argument impermissibly appeal to the jury's sympathy, but the statement did not create a substantial likelihood of a miscarriage of justice; (3) the trial judge erred in failing to instruct the jury that it could consider voluntary ingestion of drugs in determining extreme atrocity or cruelty, but the error did not create a substantial likelihood of a miscarriage of justice; (4) the judge did not err in excusing juror number fifteen; (5) the indictment charging attempted burning of a dwelling was not defective; and (6) there was no error warranting relief under Mass. Gen. Laws ch. 278, § 33E. View "Commonwealth v. Doughty" on Justia Law

The Supreme Judicial Court reversed the judgment of the superior court judge dismissing indictments against Defendants - the superintendent and medical director of the Soldiers' Home in Holyoke - for elder neglect in violation of Mass. Gen. Laws ch. 265, 13K (d 1/2) for their alleged failure to provide treatment or services to the veterans housed at Soldiers' Home, holding that the superior court judge erred in dismissing the indictments.Seventeen days after the Governor declared a state of emergency in the Commonwealth due to the COVID-19 pandemic, Defendants directed their staff to consolidate two floors of elderly veterans onto one floor, and some of the veterans were crowded into a locked space designed to house twenty-five patients at the maximum. Three days later, as many as ten veterans had died from COVID-19. The grand jury determined that probable cause existed to believe that Defendants violated the elder neglect statute. The superior court dismissed the indictments. The Supreme Judicial Court reversed, holding that the grand jury heard testimony that would warrant finding probable cause that (1) there was probable cause that Defendants were caretakers; and (2) Defendants engaged in intentional conduct of omission that involved a high degree of likelihood that substantial harm would result. View "Commonwealth v. Clinton" on Justia Law

The Supreme Judicial Court remanded this case to the district court, holding that the district court erred in denying Defendant's motion to withdraw her admission to sufficient facts.Defendant admitted to facts sufficient to support a finding of guilty to operating a motor vehicle while under the influence of intoxicating liquor (OUI), second offense, after she was informed that a breath test result showed a blood alcohol content (BAC) of 0.23 percent. After Defendant was placed on probation and her driver's license was suspended, Defendant moved to withdraw her admission to sufficient facts. The district court denied the motion. The Supreme Court remanded the case, holding (1) Defendants who pleaded guilty to an OUI offense where a breath test had been conducted using an Alcotest 9510 breathalyzer from June 1, 2011 through April 28, 2019 are entitled to a conclusive presumption that the first prong of the Scott-Ferrara test is satisfied; and (2) Defendant was entitled to withdraw her motion to withdraw her admission to sufficient facts. View "Commonwealth v. Hallinan" on Justia Law