Justia Massachusetts Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of murder in the first degree on theories of deliberate premeditation and extreme atrocity or cruelty. Defendant filed a motion for a new trial, asserting multiple claims of ineffective assistance of counsel, and requested an evidentiary hearing. The trial judge denied the motion without a hearing. The Supreme Judicial Court affirmed Defendant’s conviction and the denial of Defendant’s motion for a new trial, holding (1) Defendant failed to establish that his trial counsel provided ineffective assistance; (2) the trial judge did not err in denying Defendant an evidentiary hearing on his motion for a new trial; and (3) there was no substantial likelihood of a miscarriage of justice in the trial judge’s failure to make written findings. View "Commonwealth v. Torres" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree and armed robbery. Defendant’s convictions were affirmed on direct appeal. Defendant subsequently sought postconviction relief in both state and federal courts, without success. Defendant’s later motion for scientific testing of a jacket purportedly worn by Defendant during the killing was granted. The jacket was retested and screened negative for the presence of the victim’s blood. On the basis of the new test results, Defendant filed a motion for a new trial. The motion judge granted the motion, concluding that the jacket was a key piece of corroborative evidence against Defendant and that the newly available evidence arising from the retesting of the jacket cast real doubt on the justice of Defendant’s conviction. The Supreme Judicial Court affirmed the judgment granting Defendant’s motion for a new trial, holding that the motion judge did not abuse her discretion in ruling that physical evidence arising from the jacket served as a “real factor” in the jury’s deliberations such that the new test results “cast real doubt on the justice of the defendant’s conviction.” View "Commonwealth v. Sullivan" on Justia Law

In this case, the Supreme Judicial Court set forth a new standard for determining when substantial justice would best be served by the sealing of certain criminal records under Mass. Gen. Laws ch. 276, 100C after concluding that the stringent standard for discretionary sealing articulated nearly twenty years ago no longer achieves the proper balance of interests. Here, Defendant filed a petition to seal his criminal record pursuant to chapter 276, section 100C due to its impact on his employment opportunities. The judge denied the petition. Although Defendant attained desired relief through another process, the Supreme Judicial Court exercised its discretion to revisit the standard for discretionary sealing pursuant to chapter 276, section 100C. View "Commonwealth v. Pon" on Justia Law

After Defendant’s first three trials ended in mistrials, a fourth trial was held, and Defendant was convicted of murder in the first degree on theories of felony-murder and extreme atrocity or cruelty. Defendant appealed, raising numerous claims of error. The Supreme Court affirmed the convictions, holding (1) the trial court did not commit prejudicial error in its evidentiary rulings; (2) any error committed by the prosecutor during closing argument was not prejudicial; (3) the trial judge did not err in denying Defendant’s motion to dismiss the indictments against him; and (4) the Commonwealth engaged in egregious misconduct by issuing a press release regarding the case, but the conduct was not of sufficient significance to result in the denial of Defendant’s right to a fair trial. The Court also reinstated Defendant’s two convictions of armed robbery - the underlying felonies in the felony-murder conviction - which the trial judge had dismissed as duplicative, holding that those convictions were not duplicative where Defendant was also convicted on another theory of murder in the first degree - murder with extreme atrocity or cruelty. View "Commonwealth v. Wood" on Justia Law

Defendant was stopped by police officers while walking down the street. An officer asked for permission to search the backpack Defendant was carrying, whereupon Defendant removed the bag and handed it to the officer. The officer then removed a box designed to look like a cigarette package but which was “noticeably heavier.” At this time, Defendant changed his mind and told the officer he could not look in the bag. The officer proceeded to open the box and discovered cocaine. Defendant filed a motion to suppress the evidence seized as a result of his stop and subsequent arrest. The trial court denied the motion, and the court of appeals affirmed. Defendant was subsequently convicted of possession of cocaine with intent to distribute. Defendant appealed the denial of his motion to suppress. The Supreme Court vacated the conviction and ordered a new trial, holding (1) the investigatory stop of Defendant was supported by reasonable suspicion; but (2) there was no probable cause to make an arrest when the cigarette box was opened, and the opening of the cigarette box could not be justified as a search incident to arrest. View "Commonwealth v. Stewart" on Justia Law

Defendant was convicted of armed assault with intent to murder and unlawful possession of a firearm. Because the firearms offense for which Defendant was convicted had two applicable sentencing enhancement statutes, and the Commonwealth proved convictions of separate prior offenses for each, the judge imposed two sentences pursuant to the sentencing enhancement statutes. The Supreme Court affirmed Defendant’s convictions but remanded to the superior court with instructions that the judge vacate the sentence of one of the two sentencing enhancement counts, holding that unless the Legislature has explicitly declared its intent to permit multiple sentencing enhancements, a defendant may be sentenced under only one sentencing enhancement statute. View "Commonwealth v. Richardson" on Justia Law

Defendants were charged with firearms violations. Defendants filed motions to suppress, which the municipal court allowed. The Commonwealth appealed, but its notice of appeal was filed late in the trial court. The Commonwealth applied to a single justice of the Supreme Judicial Court for leave to appeal, but that application was also filed late. A single justice allowed the application. The Appeals Court dismissed the appeal, concluding that it lacked jurisdiction to hear the interlocutory appeal because the Commonwealth’s notice of appeal had not been timely filed. The Supreme Judicial Court granted the Commonwealth’s request for further review and (1) affirmed the order allowing the motion to suppress; and (2) set out a new framework that will apply henceforth to the manner in which the single justices of the Court should apply the procedural rules governing the timeliness of interlocutory appeals of orders on motions to suppress. View "Commonwealth v. Jordan" on Justia Law

Law enforcement officers stopped the vehicle Defendant was driving and placed Defendant under arrest on outstanding arrest warrants. The officers proceeded to pat frisk Defendant’s outer clothing and opened a container found on Defendant. Before transporting Defendant to the station for booking, an officer entered Defendant’s vehicle to retrieve its keys and saw an unlabeled container in plain view. The officer seized the pills contained in the container. Thereafter, Defendant was charged with illegal possession of methadone. Defendant moved to suppress the evidence seized as a result of his arrest on the outstanding warrants. The district court denied the motion, and the Appeals Court affirmed. The Supreme Judicial Court reversed the denial of Defendant’s motion to suppress, vacated Defendant’s conviction, and remanded for a new trial, holding that, under the circumstances of this case, the police exceeded the lawful scope of a search incident to arrest, an inventory search, and a seizure under the plain view doctrine. View "Commonwealth v. White" on Justia Law

The Sex Offender Registry Board notified Petitioner that it had preliminarily classified him as a level three sex offender. Petitioner requested a hearing. After the hearing had been completed but before the hearing examiner had rendered a decision, a successor examiner was appointed. The successor examiner then issued his decision classifying Petitioner as a level three offender. The superior court affirmed the Board’s decision. Petitioner sought an order directing the Board to produce a transcript of his classification hearing under 803 Code Mass. Regs. 4.22(4), which directs the Board to provide a successor hearing examiner and the parties with a copy of the transcript where the successor examiner is appointed after the presentation of evidence is complete and the record closed. Despite this requirement, no copy of the classification transcript was ever provided to Petitioner. Petitioner’s request was denied. Petitioner then filed a mandamus petition in the county court seeking to compel the Board to provide a copy of the hearing transcript. A single justice denied the motion. The Supreme Court vacated the judgment of the single justice and remanded the case to the county court where an order shall enter directing the Board to produce a copy of the transcript. View "Doe v. Sex Offender Registry Bd." on Justia Law

While conducting a search of the cell of Defendant, an inmate, correctional officers found seven photocopies of photographs that depicted naked children. The photographs were excerpted from a National Geographic magazine, a sociology textbook, and a naturist catalogue. Defendant moved to dismiss his ensuing indictments of child pornography and of being a habitual offender, arguing that the photocopies of the photographs did not constitute child pornography within the meaning of Mass. Gen. Laws ch. 272, 29C. The superior court allowed the motion to dismiss on the basis that none of the photocopies constituted a “lewd exhibition” of the children’s body parts as described in the statute. The Supreme Judicial Court affirmed, holding that the photocopies did not depict a “lewd exhibition,” and therefore, the judge properly dismissed the indictments on the ground that the grand jury were not presented with any evidence to support a finding of probable cause to arrest Defendant for possession of child pornography. View "Commonwealth v. Rex" on Justia Law