Justia Massachusetts Supreme Court Opinion Summaries

After a jury trial, George Labadie and Susan Carcieri, the latter of whom was employed by a federal credit union, were convicted of violating Mass. Gen. Laws. ch. 266, 52 for embezzling a “bank.” At issue on appeal was whether an employee of a federal credit union may be found guilty under section 52 of embezzlement of the credit union’s funds. The Supreme Court reversed and vacated Defendants’ convictions, holding (1) because the Commonwealth must prove under section 52 that the victim was a “bank” and because a federal credit union is not a “bank” as defined in Mass. Gen. Laws ch. 167, 1, Defendants were entitled to judgments of acquittal on this charge; (2) larceny by embezzlement is a lesser included offense of embezzlement of a bank, and federal preemption doctrine does not bar state prosecution of a federal credit union employee for larceny by embezzlement; and (3) the jury’s verdicts demonstrated that the jurors found Defendants guilty of the required elements of the lesser included offense of larceny by embezzlement. Remanded for entry of convictions of larceny by embezzlement. View "Commonwealth v. Labadie" on Justia Law

After a jury trial, Defendant was convicted of murder and related firearm charges. The appeals court affirmed. Defendant appealed, arguing that the trial court erred in denying his motion to suppress statements he made to the police during an interview at the police station. The Supreme Court affirmed, holding that the trial court did not err in admitting the statements where (1) because Defendant’s claimed invocations of the right to counsel were made before the interrogation became custodial, Defendant did not effectively invoke that right; (2) the totality of the circumstances supported the conclusion that Defendant’s statements were voluntary; and (3) even if Defendant did not validly waive his Miranda rights before making statements during the custodial portion of the interview, the admission of those statements was harmless beyond a reasonable doubt. View "Commonwealth v. Molina" on Justia Law

After a jury trial, Defendant, who was a juvenile at the time of the offense for which he was found guilty, was convicted of murder in the first degree for his knowing participation along with three other young men in the killing of the victim. The Supreme Court (1) affirmed Defendant’s conviction, holding (i) Defendant’s trial counsel did not render constitutionally deficient assistance by failing to obtain a full transcript of a witness’s testimony from another trial for impeachment purposes, (ii) the admission of state of mind evidence did not prejudice Defendant under the circumstances, and (iii) the prosecutor’s inconsistent closing argument at another trial related to the killing and Defendant’s trial did not prejudice Defendant; and (2) vacated Defendant’s sentence and remanded for resentencing, holding that Defendant’s sentence of life in prison without parole was invalid under the Eighth Amendment. View "Commonwealth v. Keo" on Justia Law

Defendant was convicted of two indictments alleging receipt of stolen property. Defendant appealed, arguing that the judge erred in denying his motion to suppress because the arrest warrants leading to the search of an apartment where the stolen property was discovered did not authorize the police to enter the apartment. Specifically, Defendant argued that the police did not have a “reasonable belief” that Defendant was present in the apartment, and therefore, the subsequent seizure of the stolen property was the fruit of this unconstitutional entry. The Supreme Court vacated the convictions and remanded, holding (1) a “reasonable belief” requires more than was known at the time of entry in this case; and (2) therefore, the entry was unconstitutional, and the observation and subsequent seizure of the stolen property allegedly received by Defendant should have been suppressed as the fruit of the illegal entry. View "Commonwealth v. Gentile" on Justia Law

Defendant was incarcerated for rape of a child when the Commonwealth filed a petition to have him declared a sexually dangerous person (SDP). Several months after the conclusion of a jury-waived trial, a superior court judge issued a decision concluding that Defendant was an SDP and ordering him committed to a treatment center. Defendant appealed, arguing, among other things, that the trial judge erred in failing to issue a decision within thirty days of the end of trial in accordance with Commonwealth v. Blake. The court of appeals affirmed. The Supreme Court affirmed, holding that although the trial judge’s decision was not issued within thirty days as required by Blake, neither dismissal of the Commonwealth’s petition nor a new trial was warranted under the circumstances. View "Commonwealth v. Pariseau" on Justia Law

After a second jury trial, Defendant was convicted of rape of a child. Prior to trial, Defendant moved to compel the production of psychological records of the complainant in the custody of the complainant’s psychologist. The motion judge denied the motion, concluding that statements by the complainant to her psychologist concerning the alleged assault, without more, did not meet the threshold requirements of Commonwealth v. Dwyer and Commonwealth v. Lampron. The court of appeals affirmed. The Supreme Court remanded the case to the superior court, holding that a summons for the production of the psychologist’s records related to the complainant’s sexual assault should have issued in this case. Remanded. View "Commonwealth v. Labroad" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on a theory of extreme atrocity or cruelty. The Supreme Court reversed and remanded for a new trial. Defendant was tried again and was again convicted of murder in the first degree on a theory of extreme atrocity or cruelty. The Supreme Court vacated the murder conviction and remanded for entry of a verdict of murder in the second degree, holding that Defendant’s mental illness and impaired mental condition drove her behavior and materially affected the fairness of a conviction of murder in the first degree on a theory of extreme atrocity or cruelty and that the unusual circumstances of this case made a verdict of murder in the second degree more consonant with justice. View "Commonwealth v. Berry" 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. The Supreme Court affirmed Defendant’s convictions and the denial of his motion for a new trial, holding (1) Defendant’s Sixth Amendment right to a public trial was not violated when the trial judge ordered that, before entering the court room, each spectator must sign in and give a source of identification to the court officer posted outside the court room; (2) the trial judge did not err by admitting into evidence grand jury testimony of a prosecution witness; (3) the admission of certain hearsay did not create a substantial likelihood of a miscarriage of justice; and (4) the trial judge did not violate Defendant’s right to be tried by an impartial jury by failing to conduct a voir dire of all the jurors after one juror expressed concern that Defendant had access to the juror’s address in the juror’s confidential questionnaire. View "Commonwealth v. Maldonado" on Justia Law

Following a jury trial nearly three years after his initial arraignment, Defendant was convicted of disorderly conduct and assault by means of a dangerous weapon. The Supreme Court reversed Defendant’s convictions and dismissed the complaints against him, holding (1) Defendant was denied a speedy trial, and any failures by his trial counsel to perfect that claim constituted ineffective assistance of counsel; and (2) the trial judge’s order of restitution to compensate a police officer whose glasses were damaged during his interaction with Defendant was constitutional under Apprendi v. New Jersey and met the “causal connection” requirement for such awards under Commonwealth v. McIntyre. View "Commonwealth v. Denehy" on Justia Law

Defendant was convicted of first degree murder on a theory of joint venture and sentenced to life in prison. Defendant appealed, arguing, among other things, that the trial judge erred in finding that he was not a target of the investigation, and because he was a target, the Commonwealth was required to advise him of his Fifth Amendment right to avoid self-incrimination. The Supreme Court affirmed, holding (1) the evidence was sufficient to permit a jury to find Defendant guilty of murder in the first degree; (2) the trial judge did not err in determining that Defendant was not a target of the investigation at the time of his grand jury testimony, but a new prospective rule requires the Commonwealth to advise targets or potential targets of the grand jury’s investigation of their right not to incriminate themselves; and (3) Defendant was not entitled to a DiGiambattista instruction where it was not requested at trial. View "Commonwealth v. Woods" on Justia Law