Justia Massachusetts Supreme Court Opinion Summaries
Articles Posted in Criminal Law
Del Gallo v. Commonwealth
The Supreme Judicial Court affirmed the judgment of a single justice of the court denying Petitioner's petition for review pursuant to Mass. Gen. Laws ch. 211, 3 and for a writ of habeas corpus pursuant to Mass. Gen. Laws ch. 248, holding that there was no error or abuse of discretion.Petitioner was charged with three offenses related to a domestic incident. Petitioner pled not guilty and then filed a motion to dismiss the complaint on the ground that there was not probable cause to charge him with a crime. A single justice denied the petition. Petitioner then filed his petition in the county court unsuccessfully challenging that order. The Supreme Judicial Court affirmed, holding that Petitioner failed to demonstrate that the single justice erred in denying relief pursuant to Mass. Gen. Laws ch. 211, 3. View "Del Gallo v. Commonwealth" on Justia Law
Posted in:
Criminal Law
Commonwealth v. Herring
The Supreme Court affirmed the judgment of the single justice of the court vacating the order of the superior court judge granting pretrial release to Defendant, holding that the single justice acted pursuant to his broad powers and within his considerable discretion.In 2017, Defendant was arraigned on various charges and held without bail. Defendant later filed multiple motions for release based on the health risk posed by the COVID-19 pandemic and exacerbated by his heart condition. The fourth motion resulted in Defendant's being released temporarily from pretrial custody subject to certain conditions. The single justice vacated the order and directed that Defendant continue to be held without bail. The Supreme Court affirmed, holding that the single justice's determination was not an abuse of discretion. View "Commonwealth v. Herring" on Justia Law
Posted in:
Criminal Law
Baxter v. Commonwealth
The Supreme Judicial Court held that the superior court erred in denying Defendant's motion to dismiss insofar as it concerned the charge of murder in the first degree on a joint venture theory, holding that there was insufficient evidence to support this conviction.Defendant charged with murder in the first degree on theories of deliberate premeditation and extreme atrocity or cruelty, accessory after the fact to murder, carrying a firearm without a license, and carrying a loaded firearm without a license. After four days of deliberations the jury deadlocked, and the trial judge declared a mistrial. Defendant then filed a motion to dismiss, arguing that a retrial would violate his right against double jeopardy. After the motion judge denied the motion Defendant filed a petition pursuant to Mass. Gen. Laws ch. 211, 3. The Supreme Judicial Court remanded the cause, holding that there was insufficient evidence that Defendant shared the lethal intent of the shooter required to support a conviction of murder in the first degree on a joint venture theory. View "Baxter v. Commonwealth" on Justia Law
Posted in:
Civil Rights, Criminal Law
Noah v. Commonwealth
The Supreme Judicial Court reversed the order of the motion judge granting a continuance sought by the Commonwealth for the express purpose of delaying resolution of the case past the juvenile's eighteenth birthday, holding that, absent certain findings, it was an abuse discretion to allow the continuance.Where the motion judge granted the continuance in this case, it meant the difference between twenty days and twelve months the juvenile spent in the custody of the Department of Youth Services. The Supreme Court reversed, holding (1) continuances for the sole purpose of extending the time of commitment are authorized only if there is clear and convincing evidence that the continued commitment is necessary for the rehabilitation of the juvenile and express findings are made to that effect after an evidentiary hearing; and (2) because no such findings were made in the instant case and the juvenile had already turned eighteen, it was an abuse of discretion to allow the continuance. View "Noah v. Commonwealth" on Justia Law
Posted in:
Criminal Law
Commonwealth v. Perry
The Supreme Judicial Court held that "tower dumps" are not per se unconstitutional and that investigators may use tower dumps so long as they comply with the warrant requirements of article 14 of the Massachusetts Declaration of Rights.The Commonwealth obtained search warrants for seven different "tower dumps," a law enforcement tool that provides investigators with the cell site location information for all devices that connected to specific cell towers during a particular time frame, corresponding to the locations of several crimes. Defendant was ultimately charged with six robberies and a homicide. Defendant moved to suppress all evidence obtained from the tower dumps as the fruit of an unconstitutional search. The superior court judge denied the motion. The Supreme Judicial Court reversed in part, holding (1) investigators may use tower dumps so long as they comply with the warrant requirements of article 14; (2) the second of the two warrants in this case was supported by probable cause and therefore did not offend the Massachusetts Declaration of Rights; but (3) the first warrant was not supported by probable cause, and any evidence obtained from it must be suppressed. View "Commonwealth v. Perry" on Justia Law
Commonwealth v. Fleury
The Supreme Judicial Court vacated the order of the superior court judge allowing the forfeiture in this case, holding that firearms found to be improperly secured according to the requirements of Mass. Gen. Laws ch. 140, 131L are not subject to forfeiture under Mass. Gen. Laws ch. 276, 3(b), which regulates the disposal of certain firearms seized during the execution of a search warrant.Police obtained a search warrant to search Defendant's home for a firearm allegedly used in an altercation. During the search, officers found that some of Defendant's more than 240 firearms appeared to be improperly secured. Defendant was subsequently indicted on twenty-seven counts of improperly securing a firearm and convicted on twelve counts. Defendant later moved for the return of all twenty-seven of the seized firearms. A superior court judge ordered the return of the firearms seized during during the execution of the search warrant with the exception of the twelve that had been found to have been improperly secured, which the judge ordered be forfeited and destroyed. The Court of Appeals vacated the order below, holding that Mass. Gen. Laws ch. 140, 129D applies only to firearms "deliver[ed] or surrender[ed]," not to those seized during a lawful search. View "Commonwealth v. Fleury" on Justia Law
Commonwealth v. Kostka
The Supreme Court affirmed Defendant's conviction of murder in the first degree and home invasion, holding that Defendant was not entitled to relief on his claims of error.On appeal from his conviction and the denial of his motion for a new trial Defendant asserted a number of allegedly erroneous evidentiary rulings, claimed that the Commonwealth failed to comply with its discovery obligations, and contended that the verdict was against the weight of the evidence. The Supreme Court affirmed, holding (1) there was no reversible error or abuse of discretion in the proceedings below; and (2) there was no reason for this Court to exercise its authority to grant relief pursuant to Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Kostka" on Justia Law
Posted in:
Criminal Law
Commonwealth v. Steadman
The Supreme Judicial Court reversed in part the denial of Defendant's motions for postconviction relief and otherwise affirmed Defendant's conviction of murder in the first degree based on both deliberate premeditation and extreme atrocity or cruelty and two counts of assault and battery by means of a dangerous weapon, holding that the trial court erred in part.Here, Defendant appealed from his convictions and from the denial of two postconviction motions. One of those motions requested forensic testing pursuant to Mass. Gen. Laws ch. 278A and the other requesting an advance of expert fees. The Supreme Judicial Court reversed in part, holding (1) as to Defendant's direct appeal there was no reversible error; (2) there was no reason to grant relief under Mass. Gen. Laws ch. 278, 33E; (3) the trial court properly denied Defendant's motion for expert fees because it was premature; but (4) Defendant's motion requesting forensic analysis met the threshold requirements of Mass. Gen. Laws ch. 278A, 3, and therefore, the trial court erred in dismissing the motion. View "Commonwealth v. Steadman" on Justia Law
Posted in:
Criminal Law
Commonwealth v. Daveiga
The Supreme Judicial Court vacated Defendant's conviction of carrying a firearm without a license, holding that the trial court erred in denying Defendant's motion to suppress.At issue was whether police officers may conduct a traffic stop on the basis of a traffic violation after having resolved the violation at a prior encounter, then having allowed the vehicle to leave, without any other traffic violation taking place. Defendant challenged the constitutionality of the traffic stop in this case under article 14 of the Massachusetts Declaration of Rights. The Supreme Judicial Court reversed the judgment of the trial court denying Defendant's motion to suppress and vacated his conviction, holding (1) police may not conduct a traffic stop on the basis of a traffic violation after having previously addressed the violation and having resolved the issue in a separate, discrete encounter; and (2) in the instant case, police lacked the authority to conduct the second traffic stop, and therefore, the stop was unreasonable under article 14. View "Commonwealth v. Daveiga" on Justia Law
Commonwealth v. DeJesus
The Supreme Judicial Court affirmed Defendant's conviction of possessing a firearm without a license and possessing a large capacity feeding device, holding that Defendant's arguments on appeal were without merit.On appeal, Defendant argued that the trial court erred by failing to suppress the firearm and the attached large capacity feeding device as the fruits of a warrantless search and that there was insufficient evidence to support the convictions. The Supreme Judicial Court affirmed, holding (1) the motion judge did not err in denying Defendant's motion to suppress; and (2) there was sufficient evidence that Defendant possessed the firearm in question. View "Commonwealth v. DeJesus" on Justia Law