Justia Massachusetts Supreme Court Opinion Summaries

Petitioners Ronald Watts and Kevin Aguirre were charged by way of complaints issued in district court with criminal offenses that Petitioners allegedly committed when they were each seventeen years old. The Governor subsequently signed St. 2013 ch. 84 (Act), which extended the juvenile court’s jurisdiction to persons who were seventeen years old at the time of committing an offense. Petitioners moved to dismiss the district court charges against them pursuant to the Act, claiming that the district courts lacked jurisdiction over them because they were seventeen at the time the alleged offenses occurred and when the criminal proceedings had begun. The Supreme Judicial Court denied Petitioners’ motions, holding that the Act does not apply retroactively to cases involving juveniles who were seventeen years of age at the time of the alleged offense and whose criminal cases in the superior court or district court were begun prior to, and were pending on, the effective date of the Act.View "Watts v. Commonwealth" on Justia Law

After a jury trial, Defendant was convicted of aggravated rape, unarmed robbery, kidnapping, carjacking, and assault and battery by means of a dangerous weapon. During trial, the State presented evidence indicating that Defendant’s DNA profile matched that of sperm found on the victim’s underwear worn on the day of the offense. For the next several years, Defendant sought, unsuccessfully, to have the sperm sample analyzed with newer and more sophisticated techniques for DNA testing. After the Legislature enacted Mass. Gen. Laws ch. 278A, Defendant filed a motion and renewed motion pursuant to Mass. Gen. Laws ch. 278A, 3 seeking more sophisticated DNA testing. The superior court denied the motions on the grounds that DNA testing already had been conducted and the evidence against Defendant was overwhelming. The Supreme Judicial Court affirmed, holding that Defendant’s motions were properly denied where the motions did not provide information demonstrating that the requested analysis had not been developed at the time of Defendant’s conviction.View "Commonwealth v. Donald" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on the theories of deliberate premeditation and extreme atrocity or cruelty and of unlawful possession of a firearm. The Supreme Judicial Court affirmed Defendant’s convictions and declined to exercise its authority pursuant to Mass. Gen. Laws ch. 278, 33E, holding (1) the trial judge’s handling of witness testimony given pursuant to grants of immunity and plea agreements did not create a substantial likelihood of a miscarriage of justice; and (2) the prosecutor’s remarks during closing argument did not amount to improper vouching. View "Commonwealth v. Webb" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on the theory of extreme atrocity or cruelty. The Supreme Judicial Court affirmed Defendant’s conviction and discerned no basis to exercise its authority pursuant to Mass. Gen. Laws ch. 278, 33E, holding (1) no substantial likelihood of a miscarriage of justice arose from the prosecutor’s use of a rhetorical question during closing arguments; (2) the trial judge did not err in refusing, over Defendant’s objection, to instruct the jury on voluntary manslaughter based on reasonable provocation; and (3) in response to a jury question, the judge did not err in reinstructing the jury of their duty to find Defendant guilty of the most serious offense that the Commonwealth had proved beyond a reasonable doubt.View "Commonwealth v. Nelson" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on a theory of extreme atrocity or cruelty for the murder of his four-year-old daughter, who died from intoxication due to sedating drugs found in her system, or from pneumonia, or from a combination of both intoxication and pneumonia. Defendant appealed his conviction and the denial of his motions for a new trial and for funds to retain a toxicologist. The Supreme Judicial Court affirmed the conviction and the orders denying Defendant’s motions, holding (1) the trial judge did not abuse his discretion in denying Defendant’s claim that his counsel was ineffective in handling the issue of toxicological evidence at trial, and trial counsel did not otherwise render ineffective assistance; (2) the evidence of malice was sufficient to support the conviction; (3) the prosecutor properly used and commented on evidence of acts Defendant committed after the charged offense to show intent or state of mind at the time of the charged offense; and (4) the trial judge did not err in denying Defendant’s motion for a new trial without an evidentiary hearing and in denying Defendant’s posttrial motion for funds to retain a forensic toxicologist.View "Commonwealth v. Riley" on Justia Law

After a jury trial, Defendant was convicted of violating a protection order issued by a judge in New Hampshire in violation of Mass. Gen. Laws ch. 209A, 7. On appeal, Defendant argued, among other things, that the trial judge erred by not instructing the jury regarding the intent required for a finding of a violation of the protection order. Specifically, Defendant argued that had she violated the protection order in New Hampshire, she could not be convicted of violating the order unless a jury found beyond a reasonable doubt that she had “knowingly” violated the order, as defined under New Hampshire law, and the same standard should apply where the alleged violation occurred in Massachusetts. The Supreme Court affirmed, holding (1) where an out-of-state abuse protection order is allegedly violated in Massachusetts and prosecuted under chapter 209A, the violation is governed by Massachusetts law and the jury should be instructed in accordance with Massachusetts law, and therefore, the judge in this case did not err by instructing the jury regarding the requirements of proof under Massachusetts law; and (2) no substantial risk of a miscarriage of justice arose with regard to the judge’s further instructions to the jury.View "Commonwealth v. Shea" on Justia Law

After receiving a telephone call from Defendant’s neighbor, police entered Defendant’s front yard without a warrant and seized three dogs, two of which appeared to be dead, that had been left outside in severely inclement winter weather. Defendant was subsequently charged with three counts of animal cruelty. Defendant filed a motion to suppress the evidence obtained as a result of the warrantless search. The superior court granted the motion but reported the question of law to the Supreme Judicial Court of whether the ‘pure emergency’ exception to the warrant requirement extends to animals. The Court answered the question in the affirmative, holding that the emergency aid exception to the warrant requirement extends to police action undertaken to render emergency assistance to animals. Remanded.View "Commonwealth v. Duncan" on Justia Law

In 2010, Defendant, who was known to be associated with a gang, was indicted for the murder of a fourteen-year-old and the wounding of a fifteen-year-old. The Commonwealth, which believed the murder was committed in connection with the gang’s criminal activities, obtained from a cooperating witness a surreptitiously recorded conversation between Defendant and other gang members, during which Defendant admitted to the killing. Defendant sought to suppress the recorded conversation as well as statements he made to the police during a post-arrest interview. The superior court denied Defendant’s motion to suppress as to all of his statements. The Supreme Judicial Court (1) affirmed the denial of the motion to suppress with respect to Defendant’s recorded conversation; but (2) reversed the denial with respect to statements Defendant made during the custodial interview after clearly invoking his right to remain silent.View "Commonwealth v. Hearns" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on theories of deliberate premeditation, extreme atrocity or cruelty, and felony-murder, and related crimes. The Supreme Judicial Court affirmed the judgments of conviction and declined to reduce the degree of guilt or order a new trial pursuant to the Court’s power under Mass. Gen. Laws ch. 278, 33E, holding (1) the trial judge did not err in its evidentiary rulings; (2) Defendant’s counsel rendered effective assistance; (3) the prosecutor did not engage in prosecutorial misconduct; and (4) the trial judge did not err in instructing the jury. View "Commonwealth v. Johnston" on Justia Law

In 2000, John Buonomo retired from his position as a Somerville alderman and began receiving pension benefits from the retirement board of Somerville (“Board”). Buonomo was subsequently elected register of probate of Middlesex County. In 2009, Buonomo was convicted of several offenses, including breaking into a depository and embezzlement by a public officer, which crimes were committed while Buonomo was register of probate. In light of Buonomo’s criminal convictions, the Board voted to forfeit Buonomo’s pension under Mass. Gen. Laws ch. 32, 15. The district court reversed the Board’s decision, determining that because the crimes for which Buonomo was convicted did not arise from his work as a Somerville alderman, for which he was receiving the retirement allowance, the Board lacked a basis for revoking Buonomo’s pension. The Supreme Judicial Court reversed, holding (1) there is no requirement in section 15 that the public office to which a board of alderman for the city of Somerville member’s criminal convictions relate be the same as the public office from which that member is receiving a retirement allowance; and (2) because Buonomo violated the laws applicable to a position of public trust, Buonomo forfeited his entitlement to a retirement allowance from the Board.View "Ret. Bd. of Somerville v. Buonomo " on Justia Law