Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed in part and vacated in part Defendant's convictions, holding that Defendant's convictions on three charges of assault by means of a dangerous weapon were duplicative.Specifically, the Supreme Judicial Court held (1) the trial court did not err in denying Defendant's motion for a new trial, motion for an evidentiary hearing, and motion for further discovery; (2) there was no prejudicial error in Defendant's convictions of murder in the first degree, three charges of armed assault with intent to commit murder, and carrying a firearm without a license; (3) Defendant's three convictions of assault by means of a dangerous weapon were duplicative of his three convictions of armed assault with intent to murder; and (4) Defendant was not entitled to relief on his remaining allegations of error; and there was no reason to grant extraordinary relief under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Fernandes" on Justia Law

The Supreme Judicial Court affirmed the order of the trial judge reducing Defendant's conviction of murder in the first degree to involuntary manslaughter pursuant to Mass. R. Crim. P. 25(b)(2), as amended, holding that the judge did not abuse her discretion by reducing the jury's verdict.Defendant was convicted of murder in the second degree on a theory of felony-murder with arson as the predicate felony. Defendant later filed this rule 23(b)(2) motion. The judge granted the motion and reduced Defendant's conviction, concluding that the weight of the evidence showed that Defendant lacked the requisite intent and also taking into account mitigating circumstances constituted by Defendant's cognitive limitations and mental disorder. The Supreme Judicial Court affirmed, holding that the reduction in Defendant's verdict was not an abuse of discretion. View "Commonwealth v. Pfeiffer" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions for murder in the first degree for the killing of Brandy Waryasz on theories of premeditation and felony-murder and murder in the first degree for the killing of Dane Anthony Hall, on a theory of felony-murder, but reversed his conviction for armed robbery, holding that the conviction must be dismissed as duplicative of the felony-murder conviction.Defendant attacked Waryasz while she was working at a gas station by tightly wrapping a ligature around her neck. Waryasz, who was seven months pregnant with Hall, died from a constricted airflow, killing her son within minutes of his mother. Defendant was indicted for two murders and armed robbery and convicted on all charges. Defendant later filed a motion for a new trial, which the superior court denied. The Supreme Judicial Court affirmed Defendant's convictions of murder in the first degree but vacated and set aside the armed robbery conviction, holding (1) as to Defendant's murder convictions, he was not entitled to relief on his allegations of error, and there was no ground for granting relief pursuant to Mass. Gen. Laws ch. 278, 33E; and (2) the armed robbery conviction was duplicative of the felony-murder conviction for the killing of Hall and therefore must be dismissed. View "Commonwealth v. Bateman" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions for deliberately premeditated murder in the first degree and unlawful possession of a firearm and declined to exercise its authority to grant extraordinary relief, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued that the trial judge erred in excluding evidence that law enforcement officers found illegal narcotics in a vehicle occupied by the victim and in the victim's clothing and that the judge's ruling "deprived the defense of the plausible alternative theory that rival drug dealers committed the murder." The Supreme Judicial Court disagreed and affirmed, holding (1) there was no evidentiary error in the proceedings below; (2) as to the firearm conviction, the trial court's failure to instruct the jury on licensure requirements was harmless beyond a reasonable doubt; and (3) the verdict of murder in the first degree was consonant with justice and should stand. View "Commonwealth v. Bookman" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of deliberately premeditated murder in the first degree and unlawful possession of a firearm and declined to exercise its extraordinary authority pursuant to Mass. Gen. Laws ch. 278, 33E to grant his a new trial or to reduce his first-degree murder conviction to a lesser degree of guilt, holding that there was no error or reason to disturb the verdicts.Together with his codefendant, Defendant was convicted of murder in the first degree on a theory of deliberate premeditation. Defendant, who was also convicted of unlawful possession of a firearm, appealed, arguing, among other things, that the trial judge erroneously excluded evidence that supported a third-party culprit defense. The Supreme Judicial Court affirmed, holding (1) the trial judge's exclusion of certain evidence did not deprive the defense "of the plausible alternative theory that rival drug dealers were responsible for the murder"; (2) there was no abuse of discretion in allowing introduction of testimony that the codefendant possessed a firearm eight months before the shooting; and (3) there was no reason to order a new trial or to reduce the degree of guilt as to the conviction of murder in the first degree. View "Commonwealth v. Acevedo" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction for murder in the first degree on the theories of deliberate premeditation and extreme atrocity or cruelty and sentence of life without parole, holding that Defendant was not entitled to relief on his allegations of error and that there was no reason to grant relief under Mass. Gen. Laws ch. 278, 33E.Specifically, the Supreme Judicial Court held (1) the motion judge did not err in denying Defendant's motion to suppress evidence from the police officers who arrested him; (2) the trial judge did not err in denying Defendant's request for a mental impairment jury instruction; (3) testimony by the Commonwealth's fingerprint analysis expert was not improper; and (4) this Court discerns no reason to grant relief under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Armstrong" on Justia Law

The Supreme Judicial Court answered a reported question in the affirmative and held that a "guilty-filed" disposition constitutes a predicate "offense" under Mass. Gen. Laws ch. 266, 30A.Defendant was charged with shoplifting, third offense, in violation of section 30A. Defendant moved to dismiss so much of the complaint that alleged a third offense on the grounds that the disposition in one of the predicate offenses on which the Commonwealth relied in support of the third offense portion of the charge was a guilty-filed disposition after Defendant pleaded guilty. The district court judge reported to the appeals court the requisition of whether a guilty-filed disposition constitutes a predicate offense under section 30A, after which Defendant entered a conditional plea to shoplifting. The Supreme Judicial Court answered the question in the affirmative, holding that a guilty-filed disposition constitutes an offense under section 30A. View "Commonwealth v. Mcneil" on Justia Law

The Supreme Judicial Court vacated Defendant's conviction of murder in the first degree and remanded this case for further proceedings, holding that the trial justice erred when he failed to instruct the jury on the impact of mental impairment and intoxication on whether Defendant acted in a cruel or atrocious manner, and this error created a substantial likelihood of a miscarriage of justice.Following a jury trial, Defendant was convicted of murder in the first degree on the theory of extreme atrocity or cruelty for the death of a woman who died from multiple chop wounds from a machete. On appeal from the denial of his motion for a new trial, Defendant argued that the trial justice erred by failing to provide two jury instructions regarding mitigating circumstances. The Supreme Judicial Court vacated Defendant's conviction, holding that the trial justice did not err by omitting Defendant's requested instructions on sudden combat but did err in failing to give an instruction on mental impairment as it related to extreme atrocity or cruelty, and the error created a substantial likelihood of a miscarriage of justice. View "Commonwealth v. Miranda" on Justia Law

The Supreme Judicial Court vacated Defendant's convictions for five counts of trafficking a person for sexual servitude and a second and subsequent offense of possession of a class A substance with intent to distribute, holding that the conflict of interest inherent in counsel's bigotry against persons of Defendant's faith and race deprived Defendant of his right to effective assistance of counsel.Defendant, a Black man of the Muslim faith, was appointed counsel who openly shared his hatred of and bigotry against people of the Muslim faith and his racism against Black persons. Counsel advised Defendant to accept a plea deal, which Defendant did. Defendant later filed a motion to withdraw his guilty plea and for a new trial, arguing that his counsel had an actual conflict of interest. The motion judge denied the motion. The Supreme Judicial Court reversed and remanded the case for a new trial, holding that Defendant met his burden to establish that counsel's representation of him was impaired by an actual conflict of interest. View "Commonwealth v. Dew" on Justia Law

The Supreme Judicial Court vacated Defendant's conviction of carrying a firearm without a license and his sentence of eighteen months in a house of correction, holding that the Commonwealth did not demonstrate beyond a reasonable doubt that Defendant knowingly, intelligently, and voluntarily waived his Miranda rights, and Defendant did not waive this issue.In a pretrial motion, Defendant filed a motion to suppress based on the alleged inadequacy of the Miranda warnings provided to him in Spanish. The motion judge denied the motion after finding that Defendant was given "the full complement of Miranda warnings" in English and in Spanish. After he was convicted and the convictions were affirmed on appeal Defendant filed a postconviction motion for a new trial, which the motion judge denied following a hearing. The appeals court affirmed. The Supreme Judicial Court vacated the conviction, holding (1) Defendant did not waive the issue of whether Miranda warnings were properly given to him in Spanish; and (2) the admission of Defendant's post arrest statements was error. View "Commonwealth v. Delossantos" on Justia Law