Justia Massachusetts Supreme Court Opinion Summaries

Defendant was convicted of unlawful distribution of cocaine and of a drug offense in a school zone. The Appeals Court, relying on its decision in Commonwealth v. King, affirmed defendant's convictions, holding that a field test and other circumstances rendered the admission of the certificate of drug analysis harmless beyond a reasonable doubt. The court granted defendant's application for further appellate review and paired this case for argument with Commonwealth v. King, a case that raised the same issue and involved the same prosecutor and the same detective as were involved in this case. Because the court concluded, as it did in King, that in the specific circumstances of this case, the Commonwealth's evidence was not so overwhelming as to nullify the effect of the erroneously admitted certificate, the judgment was reversed. View "Commonwealth v. Billings" on Justia Law

Defendant was convicted of unlawful distribution of cocaine. The Appeals court affirmed his conviction, holding that the field test and other circumstances rendered the admission of a certificate of drug analysis harmless beyond a reasonable doubt. The court granted defendant's application for further appellate review and paired this case for argument with Commonwealth v. Billings. Because the court concluded that, in the specific circumstances of this case, the Commonwealth's evidence was not so overwhelming as to nullify the effect of the erroneously admitted certificate, the judgment was reversed. View "Commonwealth v. King" on Justia Law

While being held for custodial interrogation, and without having first waived the Miranda rights of which he had been advised, defendant shook his head from side to side in response to the question, "So you don't want to speak?" At issue was whether defendant, by his conduct, had invoked the right to remain silent guaranteed under the Fifth Amendment to the United States Constitution and art. 12 of the Massachusetts Declaration of rights and, if so, whether the police sufficiently honored that right. The court concluded that, under both the Fifth Amendment and art. 12, the right to remain silent was invoked but was not "scrupulously honored" and that suppression of the subsequent incriminating statements was accordingly warranted. In so concluding, the court held that, in the prewaiver context, art. 12 did not require a suspect to invoke his right to remain silent with the utmost clarity, as required under Federal law. View "Commonwealth v. Clarke" on Justia Law

Defendant was charged with possession of a Class B substance with intent to distribute and possession of a class D substance with intent to distribute and eventually entered into a plea agreement. At issue was whether a judge had the authority under Mass. R. Crim. P. 29(a), to reduce a sentence after defendant and the Commonwealth had entered into a plea in which the Commonwealth agreed not to seek indictments against defendant on the pending charges, defendant had agreed to plead guilty to the charges and join the prosecutor's sentencing recommendation, and the judge had imposed the recommended sentence. The court concluded that where, as here, a judge acted on his own timely motion to revise or revoke a sentence, the judge had the authority to reduce a sentence where it appeared that justice may not have been done regardless whether a plea agreement included an agreed sentence recommendation. View "Commonwealth v. Rodriquez" on Justia Law

Defendant was charged in a criminal complaint with a single count of armed robbery and eventually plead guilty in the District Court to a reduced charge. At issue was whether the Commonwealth had the authority to require a judge to vacate a defendant's guilty plea where the Commonwealth made a charge concession as part of the plea agreement and the judge imposed a sentence less severe than the agreed sentence recommendation. The court concluded that the Commonwealth did not have this authority under Mass. R. Crim. P. 12, as appearing in 442 Mass. 1511, or G.L.c. 278, section 18. The court further concluded that if the guilty plea were to be vacated at the prosecution's request and over the objection of the defense, double jeopardy would bar further prosecution on that charge. View "Commonwealth v. Dean-Ganek" on Justia Law

Defendant was convicted on two indictments charging statutory rape of his fifteen year old niece. At issue was whether defendant, whose motion to stay the execution of his sentence was denied by a single justice of the Appeals Court, could file another motion to stay the execution of his sentence before a single justice of the Supreme Judicial Court after direct appellate review was granted. The court concluded that he could so proceed, and that the single justice could elect to consider de novo defendant's application for a stay. Because the court concluded that the single justice did not abuse his discretion in allowing defendant's motion to stay the execution of the sentence, the court affirmed the judgment. View "Polk v. Commonwealth" on Justia Law

Defendant was convicted, among other things, of murder in the first degree on theories of deliberate premeditation and extreme atrocity or cruelty. Defendant subsequently appealed his convictions. The court held that the evidence was sufficient to support the murder conviction; the prosecutor did misstate certain evidence at trial but the court concluded that the error did not give rise to a substantial likelihood of miscarriage of justice; and the trial judge's instructions to the jury were not erroneous. Accordingly, the court affirmed the convictions and declined to exercise its power under G.L.c. 278, section 33E, to reduce the murder verdict or order a new trial. View "Commonwealth v. Young" on Justia Law

Defendant appealed from his conviction for trafficking in over fourteen grams of cocaine. On appeal, defendant contended that the Commonwealth violated his right to confront the witnesses against him when it introduced evidence from laboratory drug tests through the testimony of a substitute analyst rather than through the analyst who performed the test. Defendant also contended that the trial judge erred in admitting certain hearsay statements and that trial counsel was constitutionally ineffective. Although much of the challenged testimony was erroneously admitted, this testimony did not create a substantial risk of a miscarriage of justice; nor was defendant denied the effective assistance of counsel. Accordingly, the court affirmed the conviction. View "Commonwealth v. Munoz" on Justia Law

Defendant appealed from his convictions of two counts of rape of a child under sixteen years of age and two counts of indecent assault and battery on a person who has attained the age of fourteen years. Defendant contended, among other things, that certain statements admitted against him at trial were obtained in violation of his Miranda rights. The court concluded that defendant unambiguously invoked his right to counsel and that questioning should have ceased until counsel was made available. Therefore, the incriminating statements should not have been admitted at trial. In any event, defendant was entitled to relief because the Commonwealth did not satisfy its heavy burden of establishing beyond a reasonable doubt that defendant's subsequent waiver of that right was knowing, voluntary, and intelligent. Because the court could not conclude that the erroneous admission of defendant's statements was harmless beyond a reasonable doubt, a new trial was required. View "Commonwealth v. Hoyt, Sr" on Justia Law

After the report and the transcript of an inquest was filed in the Superior Court, and a grand jury returned an indictment charging Amy Bishop with the murder of her brother, Globe filed a motion in the Superior Court to inspect and copy the inquest report and the transcript of the inquest proceedings. Applying the court's new standard to the inquest report and transcript at issue in this case, the court held that the denial of the motion to impound must be vacated because, as to the transcript, the judge failed to recognize the effect of G.L.c. 38, section 10, and, as to the report, the judge rested on the principle in Kennedy v. Justice of the District Court of Dukes County that the court replaced with the rule that the report became a presumptively public document when the transcript became a presumptively public document. On remand, the judge will conduct further proceedings in accordance with this opinion, with the proviso that the inquest report and transcript shall continue to be impounded until at least ten calendar days after the issuance of the rescript. View "The Globe Newspaper Co., Inc., petitioner" on Justia Law