Justia Massachusetts Supreme Court Opinion Summaries

When Plaintiff became the subject of a federal indictment, the school department (Defendant) suspended her without pay from her position as a school adjustment counselor. Ultimately, the indictment was dismissed. Plaintiff sought reinstatement to her position, but Defendant terminated her employment. Plaintiff filed a grievance challenging the termination, and an arbitrator ordered that she be reinstated. Plaintiff then filed an action seeking confirmation of the arbitration award and back pay for the period of her suspension an the period between her termination and reinstatement. The superior court affirmed the arbitration award but granted summary judgment in favor of Defendant with respect to Plaintiff's back pay claims. The appeals court affirmed the denial of back pay with respect to the period between Plaintiff's termination and reinstatement but reversed with respect to the period of her suspension. The Supreme Court affirmed. Remanded. View "Serrazina v. Springfield Pub. Schs." on Justia Law

Defendant was indicted for aggravated rape, indecent assault and battery, and other related offenses. The charges were based on five separate incidents involving five female victims. During the pretrial proceedings, the Commonwealth provided discovery to Defendant that included records related to medical treatment that some of the alleged victims received following the incidents. Defendant subsequently filed a motion for discovery that included the request for additional medical treatment or follow up visits any victim had pertaining to the indicted offenses. The superior court allowed the motion with respect to any follow up medical visits. The Commonwealth sought relief from that order, arguing that the order was improper because it required the Commonwealth to inquire of the alleged victims whether they sought or had follow-up treatment. The Supreme Court affirmed, concluding that the judge was only allowing Defendant's request to the extent it required the Commonwealth to provide information in its possession. View "Commonwealth v. Castillo" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on the theory of deliberate premeditation. Defendant appealed, arguing error in the admission of evidence, the prosecutor's closing argument, and the judge's instructions to the jury. The Supreme Court affirmed, holding (1) the trial court did not palpably err in admitting a 911 recording of the victim stating three times, "I've been stabbed"; (2) the prosecutor did not improperly attempt to evoke sympathy from the jury by playing, during his closing argument, the 911 recording; and (3) the trial court did not prejudicially err in its instructions to the jury on self-defense. View "Commonwealth v. Harris" on Justia Law

After a jury trial, Defendant was convicted of kidnapping, assault by means of a dangerous weapon, assault and battery causing serious bodily injury, assault and battery, and malicious destruction of property. The court of appeals affirmed. The Supreme Court reversed Defendant's conviction of assault and battery causing serious bodily injury, holding that the evidence, which consisted primarily of medical records not explained by an expert witness, was insufficient to permit a rational jury to find that the victim suffered "serious bodily injury" within the meaning of the relevant statute. Remanded for resentencing on the remaining convictions. View "Commonwealth v. Scott" on Justia Law

While serving a period of probation for unrelated convictions, Defendant allegedly sold crack cocaine to a confidential police informant. Prior to his probation revocation hearing, Defendant moved for disclosure of the informant's identity. The district court denied the motion. The court then revoked Defendant's probation for violation of the terms of probation. At issue on appeal was whether a defendant facing probation revocation due to an alleged new criminal offense is entitled to disclosure of the identity of an informant who was a participant in the alleged offense, the only nongovernment witness to the offense, and the only percipient witness to the entire alleged transaction. The Supreme Court vacated the district court's judgment, holding (1) under such circumstances, disclosure may be appropriate; and (2) the district court erred in denying Defendant's motion for disclosure on the ground that disclosure is never required in probation revocation proceedings. View "Commonwealth v. Kelsey" on Justia Law

Defendant was on parole from his prison sentence for armed robbery and on probation for his conviction of rape of a child when, one evening, his parole officer investigated a possible violation of her directive that Defendant remain home on Halloween to avoid congregating with children who were out trick-or-treating. When the parole officer discovered Defendant was not where he claimed to be that evening, Defendant's parole was revoked and his probation terminated. Defendant was subsequently indicted for misleading a parole officer with the intent to obstruct a criminal proceeding. The evidence at trial revealed that, on the night at issue, Defendant went to his paramour's apartment while her children were present. The trial court convicted Defendant of the charge. The Supreme Court affirmed, holding that it is a crime under Mass. Gen. Laws ch. 268, 13B for a parolee to mislead a parole officer who is investigating the parolee's possible future to comply with parole conditions, and it does not matter that the parolee failed to succeed in misleading the parole officer. View "Commonwealth v. Figueroa" on Justia Law

After a jury trial, Defendant was convicted of manslaughter. The principal question on appeal was whether, during a trial where the defendant raises a claim of self-defense and, pursuant to Commonwealth v. Adjutant, has been permitted to introduce evidence of the victim's prior violent acts on the issue of the identity of the first aggressor, the Commonwealth may introduce evidence of the defendant's prior violent acts on that same issue, to be followed by an instruction that the jury may consider the evidence of both parties' violent acts on the findings of who was the first aggressor. The Supreme Court answered yes, provided that the Commonwealth gives the defendant notice appropriately in advance of its intent to introduce such evidence and the trial judge determines that introduction of such evidence is more probative of its intended purpose than prejudicial to the defendant. In so answering, the Court affirmed the judgment of the trial court. View "Commonwealth v. Morales" on Justia Law

In 2010, a criminal complaint was filed in the district court charging Defendant with the commission of an armed robbery that took place in 2000. More than ten years after the date of the armed robbery, a grand jury returned an indictment against Defendant for that offense. The superior court dismissed the case with prejudice, concluding that the statute of limitations required an indictment to be issued and filed within ten years from the date of the offense. The Supreme Court affirmed, holding (1) the relevant statute requires the filing of an indictment within the ten-year limitations period for armed robbery; and (2) the filing of a complaint within the limitations period, and the return of an indictment outside of that period, does not constitute timely commencement of the criminal proceeding. View "Commonwealth v. Perella" on Justia Law

In 1995, Defendant was charged with assault and battery by means of a dangerous weapon and indecent assault and battery on a child under the age of fourteen. At the time, Defendant was a minor and primarily spoke Khmai. During his plea colloquy, Defendant admitted to sufficient facts and was placed on probation. Defendant was committed to the Department of Youth Services after he violated the terms of his probation. In 2009, as an adult, Defendant sought to vacate his pleas, asserting he did not knowingly and voluntarily admit to sufficient facts where no interpreter was present during his plea colloquy and where he was denied effective assistance of counsel. The juvenile court denied Defendant's motion for a new trial, and the appeals court affirmed. The Supreme Court affirmed, holding that Defendant did not provide sufficient evidence to rebut the presumption of regularity of his plea proceedings and did not demonstrate he was denied the effective assistance of counsel. View "Commonwealth v. Yardley Y." on Justia Law

Defendant had a license permitting him to carry a firearm for all lawful purposes. After driving to work one day, Defendant attempted to obtain a gun locker key for the storage of his firearm during his work shift, but all the lockers were full. Consequently, Defendant placed his gun in his vehicle's glove box and locked the vehicle. Defendant's car was later searched, and Defendant was charged with firearms violations. After a jury trial, Defendant was convicted of improperly carrying a firearm in a motor vehicle in violation of the carrying statute and unlawfully storing a firearm in violation of the storage statute. The Supreme Court reversed, holding (1) the evidence was insufficient to support Defendant's conviction under the carrying statute, and Defendant was entitled to a directed verdict of not guilty on that charge; and (2) because the trial judge did not properly instruct the jury regarding what qualifies as a locked container, Defendant's conviction under the storage statute was reversed and the case remanded for a new trial on that charge. View "Commonwealth v. Reyes" on Justia Law