Justia Massachusetts Supreme Court Opinion Summaries
Articles Posted in Criminal Law
Commonwealth v. Karen K.
The Supreme Judicial Court affirmed the decision of the juvenile court judge denying Juvenile's motion to suppress evidence of a seized firearm on the grounds that police did not have reasonable suspicion to stop her, holding that the juvenile court did not err.As a result of a report about kids displaying a firearm outside a housing complex four police officers were dispatched to the complex. One officer noticed Juvenile walking along the street who kept adjusting the waistband of her pants. The officers stopped her, conducted a patfrisk, and discovered a loaded firearm in Juvenile's waistband. After her motion to suppress was denied Juvenile entered a conditional guilty plea to four firearms-related offenses. The Supreme Judicial Court affirmed, holding that the officers had reasonable suspicion that Juvenile was carrying an illegal firearm in her waistband, and therefore, the stop and pat frisk of Juvenile comported with constitutional requirements. View "Commonwealth v. Karen K." on Justia Law
Dumas v. Commonwealth
The Supreme Judicial Court affirmed the judgment of a single justice of the court denying Petitioner's petition filed pursuant to Mass. Gen. Laws ch. 211, 3, holding that the single justice did not err or abuse his discretion in denying relief.After a jury trial, Petitioner was convicted of kidnapping, rape of a child with force, and threatening to commit a crime. The convictions were affirmed on appeal. Petitioner later filed three motions for a new trial, all of which were denied. Petitioner then filed the instant petition arguing that the appeals court erred in affirming the denial of his third new trial motion. The single justice denied relief. The Supreme Judicial Court affirmed, holding that there was no error or abuse of discretion. View "Dumas v. Commonwealth" on Justia Law
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Criminal Law
In re an Impounded Case
The Supreme Judicial Court vacated the order of a single justice of the court vacating the superior court's order that Defendant could depose the licensed social worker who saw the complaining witness, Jonathan, after Jonathan told his parents that Defendant, his technology teacher, had touched him inappropriately, holding that it was not an abuse of discretion for the motion judge to order that the social worker be subjected to a limited deposition.Defendant was indicted on charges arising from Jonathan's allegations during an interview with the Sexual Assault Intervention Network. Defendant filed a motion to examine the treatment records of the social worker who treated Jonathan, but the records had been destroyed. In response, a judge ordered that Defendant would have the opportunity to depose the social worker. Jonathan filed a petition pursuant to Mass. Gen. Laws ch. 211, 3 seeking to block the deposition. A single justice vacated the order that the social worker could be deposed. The Supreme Judicial Court vacated the single justice's order and denied Jonathan's petition for extraordinary relief, holding that it was not an abuse of discretion for the motion judge to order that the social worker be subjected to a limited deposition. View "In re an Impounded Case" on Justia Law
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Criminal Law
Kligler v. Attorney General
In this case where Plaintiffs sought a declaration that the Massachusetts Constitution protects a fundamental right to physician-assisted suicide, thereby immunizing the practice from criminal prosecution, the Supreme Judicial Court held that the proposed right, as defined by Plaintiffs, was not supported in the relevant provisions of the Constitution.Plaintiffs were a licensed physician who wished to provide physician-assisted suicide and a retired physician who had been diagnosed with an incurable cancer. Plaintiffs brought a civil action seeking declaratory and injunctive relief, arguing that terminally ill patients with six months or less to live have a constitutional right to receive a prescription for lethal medication in order to bring about death in a manner and time of their choosing. The trial court granted summary judgment for Defendants. The Supreme Judicial Court affirmed, holding (1) the Massachusetts Declaration of Rights does not protect physician-assisted suicide; and (2) the law of manslaughter prohibits physician-assisted suicide without offending constitutional protections. View "Kligler v. Attorney General" on Justia Law
Commonwealth v. Edwards
The Supreme Judicial Court reversed the judgment of the trial judge dismissing with prejudice the case against Defendant for violation of an abuse prevention order, holding that dismissal with prejudice was an abuse of discretion.During his trial, Defendant objected when the Commonwealth attempted to introduce into evidence a certificate of service of the abuse prevention order that had not been disclosed in discovery. The judge sua sponte dismissed the case with prejudice, determining that it would be fundamentally unfair to Defendant to continue with the trial or allow a retrial. The Supreme Judicial Court reversed, holding that where there was no egregious prosecutorial misconduct, the judge could have remedied the discovery violation in some other way, and there was no manifest necessity to declare a mistrial, dismissal with prejudice was an abuse of discretion and the Commonwealth was barred from retrying Defendant. View "Commonwealth v. Edwards" on Justia Law
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Criminal Law
Kifor v. Commonwealth
The Supreme Judicial Court affirmed the judgment of the county court denying, without a hearing, Petitioner's petition for relief in the nature of certiorari under Mass. Gen. Laws ch. 249, 4, holding that Petitioner failed to establish that he was entitled to extraordinary relief.In his petition, Petitioner sought to have the Supreme Judicial Court intervene in custody and child support proceedings in the probate and family court. The county court denied relief. The Supreme Judicial Court affirmed, holding that the proceedings at issue were reviewable in the ordinary appellate process and that Petitioner, who had twice before sought extraordinary relief in litigation between him and the mothers of his children, was on notice that further attempts to obtain such relief may result in the imposition of sanctions. View "Kifor v. Commonwealth" on Justia Law
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Criminal Law
Schajnovitz v. Commonwealth
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.Petitioner was charged with assault and battery on a family or household member, malicious destruction of property, and intimidation of a witness. After Petitioner unsuccessfully filed several motions to dismiss he filed his Mass. Gen. Laws ch. 211, 3 arguing that the complaint had not been signed by the correct police officer and proceeding to trial on the basis of a nonconforming criminal complaint would violate his due process rights. The previously unsigned complaint was subsequently signed and sworn in open court. Thereafter, the single justice denied Petitioner's Mass. Gen. Laws ch. 211, 3 petition. The Supreme Judicial Court affirmed, holding that there was no reason Petitioner could not obtain his desired relief in a direct appeal. View "Schajnovitz v. Commonwealth" on Justia Law
Commonwealth v. Ramos
The Supreme Judicial Court reversed the judgment of the superior court denying Defendant's motion filed under Mass. Gen. Laws ch. 278A seeking deoxyribonucleic acid (DNA) testing of fingernail clippings collected from the victim's body to support his argument that the victim was the first aggressor and that Defendant acted in self-defense, holding that the superior court erred.After a jury trial, Defendant was found guilty of murder in the first degree on a theory of deliberate premeditation. While his direct appeal was pending, Defendant brought his chapter 278A motion requesting DNA testing. A motion judge denied the motion, concluding that Defendant failed to meet the requirements of Mass. Gen. Laws ch. 278A, 7(b). The Supreme Judicial Court reversed, holding that Defendant established that a reasonably effective attorney would have requested the DNA testing and analysis. View "Commonwealth v. Ramos" on Justia Law
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Criminal Law
Commonwealth v. Narvaez
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
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Criminal Law
Commonwealth v. Kapaia
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
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Criminal Law