Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court vacated the order of the trial judge granting Defendant's motion to dismiss his criminal case for lack of prosecution and requiring the Commonwealth to file a motion to vacate it if decided to proceed with the prosecution of the case, holding that the judge's decision to require the Commonwealth to seek court approval before refiling charges was an abuse of discretion.Defendant was charged with operating a motor vehicle while under the influence, among other charges. After Defendant's trial was continued three times, he filed his motion to dismiss. The judge granted the motion and required the Commonwealth to file a motion to vacate if it chose to refile the case. The Commonwealth sought extraordinary relief under Mass. Gen. Laws ch. 211, 3, arguing that the underlying order violated the district attorney's authority to choose which cases to prosecute. The Supreme Judicial Court vacated so much of the order granting Defendant's motion to dismiss that required the Commonwealth to file a motion to vacate the dismissal, holding that the ruling constituted an unwarranted intrusion upon the powers granted exclusively to the executive branch under Article 30 of the Massachusetts Declaration of Rights. View "Commonwealth v. Rosa" on Justia Law

The Supreme Judicial Court affirmed the judgment of the motion judge allowing Defendant's motion for a new trial after the trial court convicted him of murder in the first degree, holding that the motion judge did not abuse her discretion in concluding that counsel's assistance was constitutionally ineffective.During the proceedings, counsel was informed of a proffer indicating that someone other than Defendant had gone to the victim's home on the evening of the killing and carrying the same caliber firearm as was used in the killing. In his motion for a new trial, Defendant argued that his counsel provided ineffective assistance by failing to investigate the exculpatory evidence provided by the Commonwealth. The motion judge allowed the motion. The Supreme Judicial Court affirmed, holding (1) use of the proffer evidence could have raised a reasonable doubt as to whether Defendant murdered the victim; and (2) therefore, the motion judge's denial of Defendant's motion for a new trial was an abuse of discretion. View "Commonwealth v. Tavares" on Justia Law

The Supreme Judicial Court affirmed the judgment of a single justice of the court denying Petitioner's petition pursuant to Mass. Gen. Laws ch. 211, 3, holding that the single justice did not err or abuse her discretion in denying relief.Petitioner was convicted of several crimes, including armed assault with intent to murder. The firearm leading to the charges was recovered during a motor vehicle search that led to charges in a separate case against a different individual, Danilo Depina, who successfully moved to suppress the firearm on the basis that it had been illegally seized. Petitioner later filed the underlying petition, which the county court treated as a petition pursuant to Mass. Gen. Laws ch. 211, 3, arguing that he had stand to petition the district attorney's office that had prosecuted Petitioner to produce evidence related to the firearm. A single justice denied the petition. The Supreme Judicial Court appealed, holding that there was no abuse of discretion in the denial of the appeal. View "Pina v. Commonwealth" on Justia Law

The Supreme Court affirmed Defendant's convictions for murder in the first degree on the theory of deliberate premeditation and related charges, holding that there was no reversible error in this Court's review of Defendant's direct appeal or Defendant's postconviction motion for a new trial.On appeal, Defendant challenged his convictions of murder in the first degree, armed assault with intent to murder, and assault and battery by means of a dangerous weapon causing serious bodily injury and further appealed the denial of his postconviction motion for a new trial. The Supreme Court affirmed, holding that Defendant's claims of error were unavailing and that there was no reversible error in the proceedings below. View "Commonwealth v. Kirkland" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on the theory of extreme atrocity or cruelty and his sentence of life without the possibility of parole, holding that Defendant's allegations of error were unavailing.Specifically, the Supreme Judicial Court held (1) the trial judge did not abuse his discretion in excluding proposed expert testimony regarding the general principles and characteristics of late adolescent brain development; (2) a challenged statement made by the prosecutor during closing arguments did not create a substantial likelihood of a miscarriage of justice; (3) Defendant was not entitled to an instruction on involuntary manslaughter; and (4) the jury did not apply an incorrect burden of proof in reaching their verdict; (5) this Court declines to address Defendant's challenge to the constitutionality of his sentence; and (6) this Court declines to exercise its extraordinary authority to reduce the conviction to murder in the second degree or voluntary manslaughter. View "Commonwealth v. Ridley" on Justia Law

The Supreme Judicial Court dismissed Appellant's appeal from a judgment of the county court denying, without a hearing, Appellant's petition for extraordinary relief under Mass. Gen. Laws ch. 211, 3, holding that the appeal was moot.During Appellant's criminal trial, the prosecutor experienced a medical problem requiring that he be immediately treated at a hospital. Consequently, the judge declared a mistrial and ruled that a retrial was permissible. Appellant filed a petition under Mass. Gen. Laws ch. 211, 3, arguing that there was no manifest necessity for the mistrial and that retrial would violate his constitutional protections against double jeopardy. The single justice denied relief. Thereafter, a second jury trial was held, and Appellant was convicted as charged. The Supreme Judicial Court dismissed Appellant's appeal from the denial of his Mass. Gen. Laws ch. 211, 3 petition, holding that, because Appellant's retrial had already taken place, the appeal was moot. View "Papp v. Commonwealth" on Justia Law

The Supreme Court affirmed Defendant's convictions of two counts of murder in the first degree, holding that this Court's precedent on reasonable provocation based on sudden oral revelations of infidelity, and, relatedly, lack of paternity, is hereby disavowed.Defendant stabbed his girlfriend, who was nine months pregnant, killing her and her viable fetus. At issue at trial was whether the stabbing had been mitigated by "heat of passion upon reasonable provocation," thus reducing Defendant's liability to manslaughter, because his girlfriend falsely disclosed that he was not the father. The Supreme Court affirmed, holding (1) rational jurors could have found that the stabbings were not the result of a heat of passion upon reasonable provocation, and therefore, the evidence was sufficient to support Defendant's convictions; and (2) this Court no longer recognizes that an oral discovery of infidelity satisfies the objective element of something that would provoke a reasonable person to kill his or her spouse. View "Commonwealth v. Ronchi" on Justia Law

The Supreme Judicial Court held that the presumptive ninety-day time limit on pretrial detention set forth in Mass. Gen. Laws ch. 276, 58B begins to run at the time an individual is detained, regardless of whether a formal order of detention has entered.At issue in this case was whether the presumptive time limit on pretrial detention outlined in section 58B is calculated from when an individual is first detained or from when the order of detention formally issues. Defendant asked that the docket be corrected in his dismissed case to reflect that his ninety days of detention pursuant to section 58B began to run on the date of arraignment rather than the date that the formal order of detention issued. The request was denied. Defendant then brought this petition under Mass. Gen. Laws ch. 211, 3 seeking extraordinary relief. A single justice denied the petition. The Supreme Judicial Court affirmed, holding that, where section 58B is applicable, the ninety-day clock begins to run at the time a person is detained and his or her liberty is curtailed, not when the formal order is issued. View "Velazquez v. Commonwealth" on Justia Law

The Supreme Court affirmed Defendant's conviction of murder in the first degree on a theory of deliberate premeditation and declined to exercise its authority under Mass. Gen. Laws ch. 33E either to reduce the verdict or to grant Defendant a new trial, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Judicial Court held (1) Defendant's absence from substantive sidebar conferences was error on the part of the trial court, but the error was harmless; (2) the trial judge did not abuse his discretion in ruling that a challenged statement was inadmissible hearsay and failed to satisfy one of the exceptions to the hearsay rule; (3) the trial judge did not abuse his discretion in admitting expert testimony on Defendant's military record; (4) the closure of the courtroom during jury selection did not violate Defendant's constitutional right to a public trial; (5) Defendant received effective assistance of counsel; and (6) there was no reason for the Court to exercise its discretion to reduce Defendant's conviction to murder in the second degree. View "Commonwealth v. Ng" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court denying Defendant's motion for a new trial following his conviction for murder in the first degree by means of extreme atrocity or cruelty and on the theory of felony-murder, for which his conviction of armed robbery served as the predicate offense, holding that there was no error.During trial, the Commonwealth presented expert testimony comparing hair samples collected at the crime scene with hair taken from Defendant. The testimony included a statistical probability to support the expert's opinion that the hair at issue belonged to Defendant. Due to an ensuing development finding such statistical probabilities to support hair comparisons to be unreliable Defendant filed a motion for a new trial. The motion was denied. The Supreme Judicial Court affirmed, holding that the admission of expert testimony on statistical support for hair comparison evidence, which since has been proved to be unreliable, was not a real factor in the jury's deliberations. View "Commonwealth v. Eagles" on Justia Law