Justia Massachusetts Supreme Court Opinion Summaries

Defendant was convicted of assault and battery (with his fists); assault and battery by means of a dangerous weapon (shod foot); and the unlawful possession of a firearm outside of his residence or place of business, as well as unlawful possession of a firearm having previously been convicted of a violent crime. On appeal, defendant argued, inter alia, that the firearm should have been suppressed because there was neither probable cause that a firearm would be found in the vehicle nor grounds for conducting an inventory search; the evidence was insufficient to prove that he constructively possessed the firearm; and with respect to the assault and battery convictions, defendant contended that the judge improperly permitted the jury to view a photograph of the victim's facial injuries. The court rejected defendant's arguments regarding the firearm and subsequent offender convictions, and discerned no merit in defendant's remaining claims. View "Commonwealth v. Gouse" on Justia Law

Defendant was convicted of murder in the first degree on all three theories of murder, armed robbery, and kidnapping. On appeal, defendant argued (1) error in the denial of his motion to suppress statements and evidence; (2) ineffective assistance of counsel predicated on trial counsel's failure to (a) engage a sleep deprivation expert and (b) request a jury instruction on the effect of defendant's intoxication relative to his intent; and (3) improper closing argument by the prosecutor. The court rejected defendant's arguments and affirmed the order denying the motion to suppress and the judgments of conviction. The court discerned no basis to exercise its authority under G.L.c. 278, section 33E. View "Commonwealth v. Morales" on Justia Law

Defendant was convicted of murder in the first degree on theories of deliberate premeditation and extreme atrocity or cruelty. Defendant's claims on appeal related largely to statements he made to a detective while he was in custody in a hospital recovering from a gunshot wound. Because a number of aspects of the trial, among them the detective's testimony concerning defendant's unrecorded statements, prejudicial limitations on defendant's right to cross-examine a detective, and certain of the prosecutor's remarks in closing argument, created a substantial likelihood of a miscarriage of justice, defendant was entitled to a new trial. View "Commonwealth v. Woodbine" on Justia Law

Defendant was indicted for trafficking in cocaine. On the second day of trial, defense counsel discovered that the Commonwealth had violated a discovery order by failing to copy for the defense at least 500 pages of computer-generated information obtained during the police investigation. Defendant moved to dismiss the case but, for financial and emotional reasons, objected to any declaration of a mistrial. Finding that the Commonwealth had not intentionally violated the order, the trial judge denied the motion to dismiss. The judge further found that the newly disclosed materials contained information that any "reasonably diligent" defense counsel would want to review, and that to do so would take longer than a mere "brief delay." Therefore, the judge declared a mistrial over the defendant's objection. The court held that, based upon the facts of the case, the judge did not abuse his discretion in determining that there was "manifest necessity" for a mistrial. There was no double jeopardy bar and defendant could be retried. Accordingly, the case was remanded to the county court for an entry of judgment denying the petition. View "Cruz v. Commonwealth" on Justia Law

Defendant was convicted of charges related to an armed robbery and appealed. The court concluded that the motion judge did not err in denying the motion to suppress, but that the trial judge erred in allowing the youthful offender adjudication of carjacking to be used as a predicate offense in finding defendant an armed career criminal, level three, under G.L.c. 269, section 10G(c). The court also concluded that defendant's convictions of assault by means of a dangerous weapon and armed robbery while masked were not duplicative, but that defendant's conviction of the unlawful possession of ammunition must be vacated where defendant had been convicted of carrying a loaded firearm. View "Commonwealth v. Anderson" on Justia Law

Defendant appealed from his conviction of larceny of property over $250 by false pretenses. Defendant's principal argument on appeal was that there was insufficient evidence presented to sustain his conviction. The court agreed with defendant that the evidence was insufficient and held, inter alia, that the evidence did not furnish a sufficient basis for concluding beyond a reasonable doubt that defendant knowingly made a false statement about the imminent sale of the property at issue either at the time the loan was agreed to or at the time the loan funds were disbursed. View "Commonwealth v. McCauliff" on Justia Law

Defendant was convicted of first degree murder, as well as assault and battery by means of a dangerous weapon. On appeal defendant argued that the judge failed to conduct an appropriate voir dire of the prospective jurors during jury selection; his statement to police following his arrest on the day of the killing should have been suppressed; the judge erred in admitting a statement he made to another inmate; the prosecutor's closing argument was improper and created a substantial risk of a miscarriage of justice; and the judge erred when he instructed the jury that they must consider whether defendant "as a result of a mental illness, lacked the capacity to have the intent, knowledge, or state of mind necessary" to prove the crimes charged. The court addressed each issue and affirmed the convictions. After a complete review of the record, the court declined to exercise its authority under G.L.c. 278, section 33E, to reduce the degree of guilt or order a new trial. View "Commonwealth v. Bishop" on Justia Law

Defendant was convicted of failing to verify his sex offender registration information by refusing to provide certain secondary addresses, and was sentenced to lifetime parole. On appeal, defendant argued, inter alia, that the judge erred in denying his motions for a required finding of not guilty. Because the court concluded that there was insufficient evidence to convict defendant, the court reversed. In light of this conclusion, the other issues defendant raised were moot. However, because there appeared to be some confusion concerning whether the complaint properly alleged that defendant could face lifetime parole, the court addressed it briefly. The court concluded that the complaint issued against defendant in this case did not meet requirements of art. 12. Accordingly, the judgment was reversed. View "Commonwealth v. Kateley" on Justia Law

Petitioner filed a petition for examination and discharge under G.L.c. 123A, section 9, the section of the sexually dangerous person statute that entitled someone who was committed as a sexually dangerous person annually to file a petition for examination and discharge from the Massachusetts Treatment Center. At issue was whether section 9 rendered admissible the written reports of expert witnesses retained by a section 9 petitioner for purposes of the section 9 proceeding. The court concluded that an interpretation of section 9 to bar the admission in evidence of a written report prepared by a petitioner's expert psychiatrist or psychologist, while authorizing introduction of the reports prepared by the qualified examiners and the community access board, would raise substantial due process concerns. Therefore, the court construed section 9 to render admissible petitioner's experts' written reports. The court agreed with the Appeals Court that the objected-to exclusion of the written reports prepared by petitioner's experts in this case was prejudicial and vacated the judgment of the Superior Court. View "Santos, petitioner" on Justia Law

Defendant was convicted of murder in the first degree, on theories of deliberate premeditation and felony-murder, with armed robbery as the predicate felony. On appeal, defendant claimed that he was denied a fair trial because the judge disallowed one of his peremptory challenges and barred the third-party culprit evidence he sought to present. The court held that the judge's striking of the peremptory challenge did not amount to reversible error; the "substantial connecting links" doctrine, governing the admissibility of third-party culprit evidence at criminal trials, remained a reasonable evidentiary standard that was valid under the Federal Constitution; the trial court did not err in excluding the third-party culprit evidence at issue after weighing certain considerations and correctly deeming the proffered evidence inadmissible; certain hearsay statements contained within the excluded evidence were not admissible under the then-existing mental condition exception to the hearsay rule and did not preclude the jury from assessing the relevance of the victim's relationship with defendant in considering defendant's guilt; and there was no reason to set aside the verdicts or order a new trial under G.L.c. 278, section 33E. Accordingly, the judgment was affirmed. View "Commonwealth v. Smith" on Justia Law