Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed the judgment of the district court dismissing the criminal complaint brought against Defendant for violation of Mass. Gen. Laws ch. 266, 103, holding that urine does not constitute a noxious or filthy substance within the meaning of the statute.While Defendant was being held in a jail cell in order to complete the booking process he urinated on the floor both inside and outside of his cell. Defendant was subsequently charged with vandalizing with a "noxious or filthy substance" in violation of section 103. The district court dismissed the complaint for lack of a probable cause, determining that urine was not a noxious or filthy substance under section 103. The Supreme Judicial Court affirmed, holding (1) urine is not a noxious or filthy substance within the context of section 103; and (2) therefore, the criminal complaint against Defendant lacked probable cause. View "Commonwealth v. Narvaez" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction for murder in the first degree on the theory of extreme atrocity or cruelty, holding that Defendant's allegations of error were without merit and that there was no reason to reduce the verdict pursuant to Mass. Gen. Laws ch. 278, 33E.On appeal from his conviction, Defendant argued, among other things, that there was insufficient evidence to convict him and that errors in the Commonwealth's opening and closing arguments warranted reversal. The Supreme Judicial Court disagreed and affirmed, holding (1) although portions of the prosecutor's opening statement were improper, the errors did not create a substantial likelihood of a miscarriage of justice; (2) the prosecutor misstated the accuracy of GPS data, but this error did not create a substantial likelihood of a miscarriage of justice; and (3) the prosecutor made a misstatement of evidence during her closing, but the error did not create a substantial likelihood of a miscarriage of justice. View "Commonwealth v. Kapaia" on Justia Law

The Supreme Judicial Court dismissed Appellant's appeal from a judgment of a single justice of the court denying his petition for extraordinary relief, holding that the appeal was moot.Appellant, who was serving a life sentence after being convicted of murder in the first degree, filed a petition for medical parole. While that petition was pending, Appellant filed his petition for extraordinary relief requesting an order directing the Department of Correction to create a medical parole plan. A single justice denied the petition on the basis that Appellant had an adequate alternative remedy. The Supreme Judicial Court affirmed, holding that because the petition had been denied, this appeal was moot. View "Carriere v. Department of Correction" on Justia Law

The Supreme Judicial Court vacated and set aside Appellant's conviction as a youthful offender and his adjudications of delinquency, holding that the trial judge erred in failing to conduct an inquiry into the jury foreperson's report of "discriminatory comments" being made during deliberations.Appellant, a juvenile, was found guilty for two firearm-related offenses. On appeal, Appellant argued that his right to a trial by a fair and impartial jury was twice violated at his trial. The court of appeals agreed, vacated the judgment and adjudications of delinquency, and set aside the verdicts. The Supreme Judicial Court affirmed, holding (1) the trial judge abused his discretion by not conducting a preliminary inquiry into the foreperson's report that the jury remained capable of impartially rendering a verdict; and (2) because it cannot be determined whether comments reflecting racial, ethnic, or other improper bias were made and, if so, whether they created a substantial risk of a miscarriage of justice, the case must be remanded for further proceedings. View "Commonwealth v. Ralph R." on Justia Law

The Supreme Judicial Court affirmed the judgment of the Sex Offender Registry Board initiating an upward reclassification of John Doe when he was charged with additional sex offenses, holding that there was clear and convincing evidence supporting the level three classification.In 1998, Doe pleaded guilty to the sexual assault of victim one and was classified as a level two sex offender. In 2009, Doe was found guilty of two counts of rape and abuse of a child without force and three counts of indecent assault and battery on a person age fourteen or older involving victim two. In 2010, Defendant was found guilty of two counts of rape of a child as to victim three. After Defendant was charged with the additional sex offenses relating to victims two and three, the Board notified Doe of his duty to register as a level three sex offender. The superior court and appeals court upheld the Board's decision. The Supreme Judicial Court affirmed, holding that the hearing examiner's decision was supported by substantial evidence and was not arbitrary or capricious. View "Doe v. Sex Offender Registry Bd." on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of two counts of murder in the first degree on theories of deliberate premeditation, extreme atrocity or cruelty, and felony-murder for the deaths of two anesthesiologists, holding that that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Judicial Court held (1) the prosecutor did not improperly appeal to the emotions of the jury during closing argument; (2) the trial court did not err in refusing to allow Defendant's requested changes to the model jury instruction on extreme atrocity or cruelty; (3) the judge did not err in denying Defendant's request for an instruction requiring specific unanimity on evidentiary factors; and (4) there was no error warranting relief under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Teixeira" on Justia Law

The Supreme Judicial Court affirmed the judgment of a single justice of the court denying Petitioner's petition pursuant to Mass. Gen. Laws ch. 211, 3, holding that the single justice did not err or abuse his discretion in denying relief.In his petition, Petitioner asserted claims appearing to stem from several different proceedings in the trial court and appeals court arguing, among other things, that he had been subjected to systemic fraud and "preclusion" of appeals and that his due process rights had been violated. The single justice denied the petition without holding an evidentiary hearing. The Supreme Judicial Court affirmed, holding that relief under Mass. Gen. Laws ch. 211, 3 was properly denied. View "Kifor v. Commonwealth" on Justia Law

The Supreme Judicial Court dismissed as moot Appellant's appeal from a judgment of the county court denying, without a hearing, Appellant's petition for extraordinary relief, holding that the single justice did not err or abuse his discretion by denying relief.In his petition, Appellant sought relief in the nature of mandamus compelling the Department of Correction to prepare a medical parole plan in connection with his application for medical parole. After Appellant submitted his petition his request for medical parole was denied. The Supreme Judicial Court dismissed Appellant's appeal from the judgment of the county court denying the petition, holding that the litigation was considered moot. View "Troila v. Department of Correction" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions of murder in the first degree and assault and battery by means of a dangerous weapon in the stabbing death of his former girlfriend, holding that there was no error warranting a new trial and no reason for the Court to exercise its extraordinary authority under Mass. Gen. Laws ch. 278, 33E.Specifically, the Supreme Judicial Court held (1) an expert's brief testimony concerning the legal definition of a mental disease or defect did not rise to the level of a substantial likelihood of a miscarriage of justice; (2) the trial judge did not abuse his discretion by not providing the jury a supplemental instruction distinguishing between a lack of criminal responsibility and diminished capacity; (3) there was no error in the instruction on the inference of an intent to kill that the jury could draw from the use of a dangerous weapon; and (4) the judge did not err in declining to instruct the jury to consider whether Defendant was incapable of resisting the urge to consume drugs or alcohol. View "Commonwealth v. Toolan" on Justia Law

The Supreme Judicial Court reversed the order of the trial denying Defendant's motion to vacate global positioning system (GPS) monitoring as a condition of his probation, holding that the Commonwealth failed to establish how the imposition of GPS monitoring would further its interest in enforcing the court-ordered exclusion zone surrounding the victim's home.Defendant was convicted on two indictments charging him with rape and sentenced to a term of incarceration followed by probation. As a condition of probation, the judge ordered Defendant to submit to GPS monitoring pursuant to Mass. Gen. Laws ch. 265, 47. Defendant moved to vacate the condition of GPS monitoring on the ground that it constituted an unreasonable search. The trial judge denied the motion. The Supreme Judicial Court reversed, holding that the Commonwealth did not meet its burden of establishing the constitutionality of the warrantless search. View "Commonwealth v. Roderick" on Justia Law