Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed Defendant's conviction of being an accessory before the fact to kidnapping and the order denying his motion for postconviction relief, holding that Defendant was not entitled to relief on his claims of error.Defendant, a police officer, provided several specific items to James Feeney, his drug supplier, at Feeney's request, including information about the victim as well as Defendant's police badge, gun holster, and handcuffs. Feeney provided the information and items to Scott Morrison and Alfred Ricci, who convinced the victim they were at his house to complete a mandatory drug test. The pair kidnapped him, and Feeney murdered him. Defendant was convicted of being an accessory before the fact to kidnapping. The Supreme Judicial Court affirmed the convictions and the denial of Defendant's postconviction motion, holding (1) the evidence was sufficient for a jury to find beyond a reasonable doubt that Defendant shared Feeney's intent that the kidnapping take place; (2) the trial judge's instructions to the jury were without error; and (3) there was no error in the trial judge's evidentiary rulings. View "Commonwealth v. Schoener" on Justia Law

The Supreme Judicial Court affirmed in part and reversed in part Defendant's firearm-related convictions, holding that there was probable cause to search the glove department of Defendant's car but that the judge erred in not instructing the jury on the licensure exemption set forth in Mass. Gen. Laws ch. 269, 10.After receiving a tip from a confidential informant Boston police officers searched Defendant's vehicle without a warrant and discovered a loaded firearm and large capacity magazine in the glove compartment. At issue on appeal was whether the trial judge erred in not instructing the jury on either of the two exemptions contained in Mass. Gen. Laws ch. 269, 10. The Supreme Judicial Court held (1) in order to convict a defendant of unlawful possession of a firearm due process requires the Commonwealth to prove beyond a reasonable doubt that a defendant did not have a valid firearms license, and therefore, Defendant's convictions of unlawful possession of a firearm, unlawful possession of a loaded firearm, and unlawful possession of ammunition could not stand; and (2) because there is no constitutional right to possess a large capacity magazine, Defendant's conviction of unlawful possession of a large capacity feeding device is affirmed. View "Commonwealth v. Guardado" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial judge revoking Defendant's probation and sentencing him to two years in a house of correction followed by one year of probation, holding that the wiretap statute, Mass. Gen. Laws ch. 272, 99, did not preclude the use of born-worn camera footage at Defendant's probation violation proceeding.While on probation for assault and battery and for violating an abuse prevention order Defendant forcibly entered his girlfriend's residence over her objection and assaulted her. After a domestic disturbance call, police officers arrived at the victim's residence. One officer activated his body-worn camera before entering the premise and captured audio-visual footage of the victim's reporting of the events that had transpired, the state of her home within his plain view, and his interview with the victim's daughters. At issue was whether the wiretap statute precluded the use of the body-worn camera footage at the probation violating proceeding or whether the recording violated Defendant's constitutional rights. The Supreme Court answered both questions in the negative, holding that Defendant was not entitled to relief on his allegations of error. View "Commonwealth v. Rainey" on Justia Law

The Supreme Judicial Court affirmed the judgments of probation entered in separate superior court cases stemming from the same adjudication, holding that the State proved by a preponderance of the evidence that Defendant had violated the terms and conditions of his probation.After a hearing, the hearing justice found that Defendant had violated the terms of his probation in two cases and removed three and a half years suspension on each sentence in those cases. On appeal, Defendant argued that the State did not prove by a preponderance of the evidence that he violated the terms and conditions of his probation. The Supreme Judicial Court affirmed, holding that the hearing justice did not act arbitrarily or capriciously in finding a violation. View "Carver v. Commissioner of Correction" on Justia Law

The Supreme Judicial Court remanded this matter to the Commissioner of Correction in this appeal from the denial of medical parole, holding that the Commissioner's decision was arbitrary and capricious because it was made without the benefit of a standardized risk assessment required by Title 501 Code Mass. Regs. 17.02.Appellant, a sixty-six-year-old man serving a life sentence without the possibility of parole in connection with his first-degree murder conviction, petitioned for medical parole under Mass. Gen. Laws ch. 127, 119A arguing that he was permanently incapacitated and unlikely to return to violating the law if released. The Commissioner denied the request, determining that there was not a "significant and material" change in Plaintiff's circumstances. Plaintiff then commenced this action pursuant to Mass. Gen. Laws ch. 249, 4. A superior court denied the motion, finding that the Commissioner's decision was reasonable. The Supreme Judicial Court reversed, holding that the Commissioner's decision to deny Plaintiff medical parole was erroneous because a risk assessment was not conducted on him. View "McCauley v. Superintendent, Mass. Correctional Institution, Norfolk" on Justia Law

The Supreme Judicial Court affirmed the order of the superior court denying Defendant's motion to suppress, holding that the articulable facts combined to establish reasonable suspicion that Defendant had committed armed robbery.At issue was whether information known to other investigating officers may be imputed to the officer who initiated the stop under the collective knowledge doctrine. The superior court judge denied Defendant's motion to suppress evidence obtained as a result of a stop, concluding that the officer who conducted an investigatory stop on Defendant had adequate reasonable suspicion to do so. The appeals court affirmed. The Supreme Judicial Court affirmed, holding that, with or without the imputed knowledge, the officer who stopped Defendant had reasonable suspicion to do so. View "Commonwealth v. Privette" on Justia Law

The Supreme Judicial Court affirmed the order finding Probationer in violation of his probation, revoking his probation and imposing the remainder of his suspended sentence, holding that the evidence was sufficient to for the superior court judge to find, by a preponderance of the evidence, that Probationer had violated a term of his probation by committing a new offense.On appeal, Probationer argued that the judge erroneously relied upon an unreliable, in-court identification by a witness who had made no prior, out-of-court identification. Specifically, Probationer asked the Supreme Judicial Court to extend the rule set forth in Commonwealth v. Crayton, 470 Mass. 228, 214 (2014), excluding such identifications in criminal trials without a showing of good reason to probation violation hearings. The Supreme Judicial Court affirmed, holding (1) this Court declines to extend Crayton to probation violation hearings; and (2) sufficient evidence supported the holding that Probationer had violated a term of his probation by committing a new offense. View "Commonwealth v. Jarrett" on Justia Law

The Supreme Judicial Court held that the single justice of the county court neither erred nor abused his discretion by denying, without a hearing, Petitioner's petition for relief under Mass. Gen. Laws ch. 211, 3, holding that the single justice neither erred nor abused his discretion by denying extraordinary relief.In 1985, Petitioner was convicted of aggravated rape and other offenses. In 2005, the Sex Offender Registration Board issued a decision ordering Petitioner to register as a level three sex offender, thereafter denying Petitioner's motion for relief from the registration requirement. In this petition, Petitioner brought, among other claims, constitutional challenges to both federal and state sex offender registration laws. The single justice denied relief. The Supreme Judicial Court affirmed, holding that the single justice did not abuse his discretion in finding that no exceptional circumstances were present in this case warranting extraordinary relief. View "Rancourt v. Attorney General" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court judge denying Defendant's motion to enforce a plea bargain, holding that the plea offer did not violate Defendant's rights to due process.Defendant was indicted along with two codefendants on two counts of murder in the first degree. Defendant was offered a "package deal" plea bargain under which he would have been able to plead guilty to manslaughter if his codefendant also agreed to the same plea. Defendant's codefendant refused the terms of the agreement. Defendant and his codefendant were tried and convicted of all charges. Defendant later filed a motion to vacate his convictions and to accept pleas to manslaughter, as the Commonwealth had originally offered, arguing that the condition attached to the plea offer violated his right to decide whether to accept the plea or go to trial. A superior court judge denied the motion. The Supreme Judicial Court affirmed, holding that the superior court did not err in denying Defendant's motion to enforce the plea bargain. View "Commonwealth v. DiBenedetto" on Justia Law

The Supreme Judicial Court remanded this matter to the county court for entry of an order dismissing the Commonwealth's gatekeeper petition filed under Mass. Gen. Laws ch. 278, 33E challenging the decision of the superior court judge granting Defendant's motion for postconviction relief and reducing his conviction, holding that the petition was untimely.Defendant served forty-four years in prison for his conviction of murder in the first degree. In 2020, Defendant filed a postconviction motion to reduce the verdict from murder in the first degree to murder in the second degree on the grounds that the Commonwealth's 1978 package plea offer violated his right to due process. The motion judge granted the motion and, in 2021, reduced the verdict to murder in the second degree. The Commonwealth filed a notice of appeal but did not file the gatekeeper petition until five and one-half months later, exceeding the thirty-day time limit set out in Mains v. Commonwealth, 433 Mass. 30, 36 n.10 (2000). After a remand, the single justice allowed the petition. The Supreme Judicial Court remanded the matter for entry of an order dismissing the Commonwealth's gatekeeper petition, holding that, with respect to filing deadlines, the Commonwealth is subject to the limitations established in Mains. View "Commonwealth v. Smith" on Justia Law