Justia Massachusetts Supreme Court Opinion Summaries

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

Defendant was convicted of murder in the first degree by reason of extreme atrocity or cruelty. Defendant appealed. The court concluded that the Commonwealth's evidence was sufficient to warrant a finding by the jury beyond a reasonable doubt that defendant was guilty of murder in the first degree based on extreme atrocity or cruelty. The court also held that no substantial likelihood of miscarriage occurred where the evidence did not warrant a voluntary manslaughter instruction based on heat of passion induced by sudden combat. Because defendant received the benefit of an instruction to which he was not entitled, any errors in the instruction could not have prejudiced him. The court further held that the judge correctly excluded the evidence of the victim's prior violent conduct. Finally, the court concluded that there was no reason to exercise its authority under G.L.c. 278, section 33E. Accordingly, the judgment was affirmed. View "Commonwealth v. Rodriquez" on Justia Law

Defendant was found guilty of rape of a child and indecent assault and battery on a child under the age of fourteen. On appeal, defendant challenged the admission of testimony concerning a "second complaint" made by the victim. The court concluded that, under the first complaint doctrine, the Commonwealth was not entitled to present evidence, either from the victim or her mother, pertaining to the victim's disclosure to her grandmother. However, the court further concluded that, in the circumstances of this case, the admission of such evidence did not constitute prejudicial error because it was properly admitted to rebut defendant's suggestion that the victim had fabricated her accusations against him. The court modified the scope of judicial review of decisions on the admissibility of testimony pursuant to the "first complaint" doctrine set forth in Commonwealth v. King and its progeny. Defendant also challenged the admission, under the doctrine of verbal completeness, of a prior consistent statement made by the victim during her grand jury testimony. The court concluded that all the components of the verbal completeness doctrine were met and defendant had not demonstrated that the judge abused her discretion when she admitted the additional portion of the victim's grand jury testimony. Therefore, there was no error. Accordingly, the judgment was affirmed. View "Commonwealth v. Aviles" on Justia Law

Defendant was found guilty of unlawful possession of a firearm, unlawful possession of ammunition, unlawful possession of a loaded firearm, resisting arrest, and operating a motor vehicle with a suspended license and subsequently convicted of being an armed career criminal. Defendant raised three issues on appeal. The court held that the Superior Court judge did not err in denying defendant's motion to suppress the firearm, ammunition, and marijuana seized from his vehicle where there was ample probable cause to permit a search of defendant's motor vehicle under the automobile exception to the warrant. The court held, however, that defendant's convictions of unlawful possession of ammunition and unlawful possession of a loaded firearm were duplicative, and his separate sentences for each crime violated the double jeopardy clause because he was punished twice for possession of the same ammunition. This error gave rise to a substantial risk of miscarriage of justice and therefore, defendant's conviction and sentence on the lesser included offense of unlawful possession of ammunition was vacated. The court further held that the requirement of licensing before one could possess a firearm or ammunition did not by itself render the licensing statute unconstitutional on its face and therefore, defendant's challenge to the Commonwealth's statutory licensing scheme failed. View "Commonwealth v. Johnson" on Justia Law

Defendant was convicted of murder in the first degree on theories of deliberate premeditation and extreme atrocity or cruelty. On appeal, defendant argued, among other things, that the conviction must be overturned because (1) closure of the court room during jury selection violated his constitutional right to a public trial under the Sixth Amendment; (2) defendant improperly was precluded from presenting evidence of potential third-party culprits; (3) one of the Commonwealth's DNA experts offered improper testimony; (4) the Commonwealth failed to make timely disclosure of expert materials; (5) the prosecutor's closing argument was improper; and (6) trial counsel was ineffective. Defendant further argued that the motion judge erred in ruling on his motions for a new trial without holding an evidentiary hearing. The court affirmed the conviction, the orders denying defendant's motion for a new trial and his supplemental motion for a new trial, and declined to grant relief under G.L.c. 278, section 33E. View "Commonwealth v. Buckman" on Justia Law