Justia Massachusetts Supreme Court Opinion Summaries

Defendant was convicted of murder in the first degree and sentenced to a mandatory term of life imprisonment without the possibility of parole. Defendant was seventeen years old at the time of the offense. The U.S. Supreme Court subsequently decided Miller v. Alabama, which held that the imposition of a mandatory sentence of life imprisonment without parole on persons under the age of eighteen at the time they committed the murder violates the Eighth Amendment. Consequently, Defendant filed a petition challenging the constitutionality of the sentencing scheme for murder in the first degree as applied and sought a declaration that article 26 of the Massachusetts Declaration of Rights bars the imposition of a sentence of life imprisonment for juvenile homicide offenders. The Supreme Court held (1) Miller has retroactive application to cases on collateral review; and (2) the mandatory imposition of a sentence of life in prison without the possibility of parole on individuals who were under age eighteen when they committed first degree murder violates the prohibition on cruel or unusual punishments in article 26, and the discretionary imposition of such a sentence on juvenile homicide offenders also violates article 26 because it is an unconstitutionally disproportionate punishment. View "Diatchenko v. Dist. Attorney" on Justia Law

Defendant committed murder when he was seventeen years old. Defendant was subsequently convicted in the superior court of murder in the first degree and related weapons charges. While Brown was awaiting trial, the U.S. Supreme Court decided Miller v. Alabama, which held that mandatory life-without-parole sentences for juvenile homicide offenders violate the Eighth Amendment. The statutory sentencing scheme in Massachusetts requires, however, that all defendants over the age of fourteen who are convicted of murder in the first degree must be sentenced to life without the possibility of parole. Consequently, Defendant's sentencing was stayed until the Maine Supreme Court could render an opinion regarding the issue. The Supreme Court concluded that Defendant was entitled to the benefit of Miller and Commonwealth v. Diatchenko, in which the Court held that all life-without-parole sentences for juvenile offenders violate the Massachusetts Declaration of Rights. Consequently, the Court held that Defendant may not be sentenced to life without parole. Remanded for sentencing. View "Commonwealth v. Brown" on Justia Law

Petitioner was indicted on charges of murder, unlawful possession of a firearm, and attempted armed robbery, among other charges. The Commonwealth filed a motion for a protective order to limit the discovery of witnesses' identifying information. A judge allowed the motion in part, ordering that witnesses' addresses and telephone numbers not be disclosed to Petitioner. Petitioner filed this petition for review pursuant to Mass. Gen. Laws ch. 211,3 arguing that the order deprived him of his constitutional rights, including his ability to prepare a defense. A single justice denied relief. The Supreme Court affirmed, holding that Petitioner's issues could be adequately and effectively explored on direct appeal, if and when Petitioner was convicted. View "Madison v. Commonwealth" on Justia Law

John Doe, a female, pleaded guilty to several federal charges stemming from her prior management of an escort service, including sex trafficking of children. A hearing examiner of the Sex Offender Registry Board (SORB) classified Doe as a level one sex offender after determining that Doe presented a low risk of reoffense and attendant degree of dangerousness. The superior court affirmed SORB's classification determination of Doe as a level one sex offender. The Supreme Court vacated the judgment of the superior court and remanded the matter to SORB, holding (1) it was arbitrary and capricious for SORB to classify Doe's risk of reoffense and degree of dangerousness without considering the substantial evidence presented at the hearing regarding the effect of gender on recidivism; and (2) under the circumstances, the hearing examiner abused his discretion by denying Doe's motion for funds for an expert witness. View "Doe v. Sex Offender Registry Bd." on Justia Law

On August 20, 2009, Defendant was charged with possession of a class B substance with intent to distribute and committing this violation within 1,000 feet of a preschool facility in violation of Mass. Gen. Laws ch. 94C, 32J. While Defendant's case was pending, on August 2, 2012, the Governor signed into law a crime bill that amended chapter 94C section 32J by reducing the radius of the school zone from 1,000 feet to 300 feet. Thereafter, Defendant moved to dismiss his school zone violation, alleging that the crime bill applied to all cases alleging a school zone violation that had not been adjudicated before August 2, 2012. The trial judge denied the motion. The Supreme Court vacated the judge's order, holding that the portion of the crime bill reducing the radius of the school zone applies to all cases alleging a school zone violation for which a guilty plea had not been accepted or conviction entered as of August 2, 2012, regardless whether the alleged violation was committed before that date. Remanded. View "Commonwealth v. Pagan" on Justia Law

After a jury-waived trial, Defendant was convicted of operating a motor vehicle after his license had been suspended for operating while under the influence of alcohol (OUI). The court of appeals affirmed the conviction. The Supreme Court reversed Defendant's conviction, holding (1) the admission of certain documents from the registry of motor vehicles without live testimony from a registry employee violated Defendant's confrontation rights to the extent that the registry documents included an attestation of notice, and the error was not harmless beyond a reasonable doubt; and (2) the Commonwealth presented sufficient evidence that Defendant violated Mass. Gen. Laws ch. 90, 23, third par, which governs operating a motor vehicle after suspension of a license on the basis of an OUI, and therefore, the judge erred in imposing a sixty-day sentence. View "Commonwealth v. Lee" on Justia Law

Defendant was charged with possession of a class D substance with intent to distribute and committing this violation within 1,000 feet of a preschool facility in violation of Mass. Gen. Laws ch. 94C, 32J. While Defendant's case was pending, on August 2, 2012, the Governor signed into law a crime bill that amended chapter 94C section 32J by reducing the radius of the school zone from 1,000 feet to 300 feet. Defendant moved to dismiss the school zone violation, claiming that the crime bill applied to all cases alleging a school zone violation that had not been adjudicated before August 2, 2012. The Supreme Court held that the portion of the crime bill that reduces the radius of the Drug-Free School Zone from 1,000 feet to 300 feet applied to all cases alleging a school zone violation for which a guilty plea had not been accepted or conviction entered as of August 2, 2012, regardless of whether the alleged violation was committed before August 2, 2012. Remanded. View "Commonwealth v. Bradley" on Justia Law

In 1996, Defendant pled guilty to various offenses, including uttering a false instrument, larceny, and receiving stolen property. Fifteen years later, Defendant filed a motion to withdraw his guilty pleas, contending that the plea judge did not conduct a sufficient colloquy regarding his rights to a trial by jury. The plea judge that accepted Defendant's guilty pleas allowed Defendant's motion to withdraw his pleas after declining to apply a presumption of regularity to the proceeding because the judge lacked confidence that his plea colloquy had been adequate. The Supreme Court vacated the judge's order, holding that the judge's belief that certain plea colloquies he conducted over a period of years may have been inadequate was insufficient to dispel the presumption of regularity or to support the withdrawal of Defendant's pleas. Remanded. View "Commonwealth v. Cartagena" on Justia Law

After a police officer stopped Defendant's vehicle and conducted two field sobriety tests, the officer arrested Defendant. Defendant pleaded guilty to several alcohol-related driving offenses. After a jury trial, Defendant was convicted of additional alcohol-related driving offenses. The Supreme Court affirmed the judgments, holding (1) the trial judge erred in admitting the officer's opinion that Defendant's "ability to drive was diminished" by his consumption of alcohol, but the error was harmless; (2) the trial judge did not err in admitting the officer's opinion that Defendant was "probably impaired"; and (3) where the indictment charging Defendant identified the statute that Defendant allegedly violated but failed to allege an essential element of proof in describing the offense, due process did not require vacating the Defendant's conviction arising from his guilty plea where he had fair notice of the crime charged and failed to show that he did not understand that he was pleading guilty to the crime. View "Commonwealth v. Canty" on Justia Law

Defendant was stopped and subsequently arrested at a sobriety checkpoint conducted by the state police. Thereafter, Defendant was charged with operating under the influence of alcohol, third offense. Defendant filed a motion to suppress evidence related to his arrest, arguing that the officer who made the initial stop of the vehicles passing through the checkpoint - the screening officer - failed to comply with the applicable guidelines for that checkpoint. The district court judge allowed the motion. On appeal, the parties agreed that the judge based his decision to allow the motion to suppress on an erroneous finding of fact. The point of dispute was whether the screening officer had the authority to question Defendant before directing him to a secondary screening area. The Supreme Court vacated the order allowing the motion to suppress, holding that a factual finding must be made as to whether the officer's questions were proper or improper according to the guidelines applicable to the particular sobriety checkpoint at which Defendant was stopped. Remanded. View "Commonwealth v. Gray" on Justia Law