Justia Massachusetts Supreme Court Opinion Summaries

After a jury-waived trial, Defendant was convicted of possession of cocaine with intent to distribute. On appeal, Defendant argued, among other things, that his counsel provided ineffective assistance for failing to strike a portion of the testimony of the Commonwealth’s expert witness. The Supreme Judicial Court reversed the conviction and remanded for a new trial, holding (1) because counsel did not move to strike the expert witness’s nonresponsive answer, the Commonwealth was provided with the proof it needed to survive a motion for a required finding of not guilty as to the element of intent to distribute; and (2) a new trial was required for the Commonwealth to present the testimony of a witness whose statements were allegedly relied upon by the Commonwealth’s expert. View "Commonwealth v. Sepheus" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on a theory of deliberate premeditation. Defendant appealed, raising five claims of error. The Supreme Judicial Court reversed Defendant’s conviction, holding (1) the trial judge erred in furnishing the jury with an instruction in accordance with Commonwealth v. Rodriquez and Commonwealth v. Tuey, as a reasonable jury listening to this instruction would have understood that, if they were unable to reach a verdict with respect to murder in the first degree, a mistrial would be declared, and the case would need to be retried; and (2) the error created a substantial likelihood of a miscarriage of justice with respect to the jury’s decision to convict Defendant of murder in the first degree rather than murder in the second degree. Remanded. View "Commonwealth v. Figueroa" on Justia Law

After a jury trial, Defendant was found guilty of enticement of a child and four counts of attempting to commit certain offenses, including rape of a child, indecent assault and battery on a child, and disseminating matter harmful to a minor. The appeals court affirmed the convictions of enticement of a child, attempted rape, and attempted indecent assault and battery and vacated the convictions of disseminating matter harmful to a minor. The Supreme Court affirmed the conviction of enticement of a child and reversed the convictions of attempt, holding (1) the evidence was insufficient to support Defendant’s convictions of attempted rape, attempted indecent assault and battery, and dissemination of matter harmful to a minor; and (2) the evidence was sufficient to support Defendant’s conviction of enticement of a child, the judge did not abuse his discretion in allowing the introduction of certain photographs notwithstanding the Commonwealth’s prior stipulation not to introduce the photographs, and the police did not violate Defendant’s constitutional rights by searching his computer for evidence.View "Commonwealth v. Buswell" on Justia Law

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