Justia Massachusetts Supreme Court Opinion Summaries
Articles Posted in Criminal Law
Commonwealth v. Hinds
The defendant was convicted of two counts of assault and battery by means of a dangerous weapon after attacking two victims with a hammer. The defendant admitted to hitting the victims but claimed self-defense. During the trial, the prosecution introduced a text message and social media posts to demonstrate the defendant's animosity toward the victims. The defendant sought to call an expert to dispute the authenticity of these posts, but the trial judge excluded the expert's testimony due to untimely disclosure.The case was first tried in the Superior Court, where the defendant was found guilty of more severe charges. On appeal, the Supreme Judicial Court reversed the convictions and ordered a new trial due to the improper exclusion of expert testimony. In the retrial, the defendant was convicted of the lesser included offense of assault and battery by means of a dangerous weapon. The Appeals Court later reversed these convictions, finding errors in the admission of the social media posts and the exclusion of the expert testimony. The Supreme Judicial Court then granted further appellate review.The Supreme Judicial Court of Massachusetts affirmed the trial court's decisions. The court held that the text message and social media posts were admissible as they were probative of the defendant's animus and intent, and their probative value was not outweighed by the risk of unfair prejudice. The court also found no abuse of discretion in excluding the expert testimony, as the late disclosure prejudiced the Commonwealth and the testimony was minimally material to the case's outcome. The judgments were affirmed. View "Commonwealth v. Hinds" on Justia Law
Posted in:
Criminal Law
Commonwealth v. Rogers
In 2007, the defendant was convicted of first-degree murder on a felony-murder theory, with armed robbery as the predicate felony, and assault and battery by means of a dangerous weapon. The incident involved the defendant shoplifting, being confronted by store employees, and subsequently stabbing two employees, resulting in one death. The defendant's convictions were affirmed on direct appeal in 2011.In 2018, the defendant filed a motion for a new trial, claiming ineffective assistance of counsel for not employing a neuropsychologist to support a mental impairment defense. He also renewed a motion to reduce the verdict. A Superior Court judge held an evidentiary hearing in 2021, where expert testimony suggested the defendant's intent was impaired by panic during the incident. The motion judge denied the new trial motion but reduced the verdict to second-degree murder, citing a sense of injustice and referencing a recent legal standard requiring actual malice for murder convictions.The Supreme Judicial Court of Massachusetts reviewed the case. It affirmed the denial of the new trial motion, agreeing that the failure to present the mental impairment defense did not deprive the defendant of a substantial ground of defense. However, the court found that the motion judge abused his discretion in reducing the verdict. The reduction was improperly based on the sentence for first-degree murder and the judge's interpretation of a recent legal standard not applicable to the case. The court reversed the reduction of the verdict, reinstating the first-degree murder conviction. View "Commonwealth v. Rogers" on Justia Law
Posted in:
Criminal Law
Commonwealth v. Dilworth
The case involves the defendant, who was indicted for unlawful possession of a firearm and related offenses after Boston police officers monitored his Snapchat account and observed him brandishing firearms in several videos. The police used an undercover Snapchat account to send a friend request to the defendant, who accepted it, allowing the officers to view his posts. The defendant was arrested twice, once in January 2018 and again in May 2018, each time after posting videos showing him with firearms.In the Superior Court, the defendant filed multiple discovery motions seeking information about the Boston Police Department's (BPD) use of undercover social media monitoring, arguing that it was relevant to an equal protection claim of discriminatory enforcement. The court granted these motions, ordering the Commonwealth to disclose various pieces of information, including the usernames and profile images used by undercover officers. The Commonwealth refused to comply, citing concerns about compromising ongoing investigations and endangering informants.The Supreme Judicial Court of Massachusetts reviewed the case. The court held that the Commonwealth did not properly assert a privilege to withhold the requested information, as it failed to demonstrate a legitimate need to protect ongoing investigations or the safety of informants. The court also affirmed the lower court's application of the equal protection standard from Commonwealth v. Long, which applies to claims of discriminatory law enforcement practices beyond traffic stops.The court concluded that the Superior Court judge did not abuse his discretion in dismissing the indictments with prejudice as a sanction for the Commonwealth's deliberate non-compliance with the discovery order. The dismissal was deemed appropriate because the Commonwealth's refusal to provide the requested discovery denied the defendant the opportunity to develop his equal protection claim, thus preventing a fair trial. View "Commonwealth v. Dilworth" on Justia Law
Posted in:
Civil Rights, Criminal Law
Commonwealth v. Gaines
In December 1974, Peter Sulfaro was shot and killed during an armed robbery at his shoe repair shop. His son, Paul Sulfaro, was the only witness. Three men, including Raymond Gaines, were convicted of the crime. Decades later, Gaines filed a motion for a new trial, citing new evidence and issues with the original trial.Gaines's convictions were affirmed by the Supreme Judicial Court of Massachusetts in 1978. He made several unsuccessful attempts for postconviction relief. In 2021, he filed his fourth motion for a new trial, which was granted by a Superior Court judge. The Commonwealth appealed this decision to the Supreme Judicial Court for the county of Suffolk.The Supreme Judicial Court of Massachusetts reviewed the case and upheld the decision to grant a new trial. The court found that new scientific research on eyewitness identification, which was not available at the time of the original trial, could have significantly impacted the jury's deliberations. Additionally, the court found that the Commonwealth failed to disclose exculpatory evidence, including a note about a leg injury Gaines sustained before the crime and the arrest of a key witness, David Bass, which could have been used to challenge his credibility. The court also noted that the Commonwealth had an ethical duty to disclose any witness recantations, regardless of their credibility or timing.The court concluded that the combination of these factors indicated that justice may not have been done in the original trial, and therefore, a new trial was warranted. The decision to grant a new trial was affirmed. View "Commonwealth v. Gaines" on Justia Law
Commonwealth v. Canjura
The case involves the defendant, David E. Canjura, who was arrested by Boston police officers on July 3, 2020, after an altercation with his girlfriend. During a search incident to the arrest, officers found a spring-assisted knife on Canjura. He was charged with carrying a dangerous weapon under G. L. c. 269, § 10 (b), and assault and battery on a family or household member. Canjura conceded the knife met the statutory definition of a switchblade but challenged the constitutionality of the statute under the Second Amendment.In the Boston Municipal Court, Canjura filed a motion to dismiss the charge, arguing that the statute violated his Second Amendment rights. The judge denied the motion, and Canjura entered a conditional plea, reserving his right to appeal. The court accepted his plea and placed him on administrative probation, while the assault and battery charge was dismissed at the Commonwealth's request. Canjura appealed, and the Supreme Judicial Court of Massachusetts granted direct appellate review.The Supreme Judicial Court of Massachusetts reviewed the case and applied the two-part test from New York State Rifle & Pistol Ass'n v. Bruen. The court first determined that switchblades are "arms" under the Second Amendment, as they fit historical definitions and were commonly used for lawful purposes at the time of the founding. The court then examined whether the statute was consistent with the nation's historical tradition of arms regulation. Finding no historical analogues to justify the regulation of switchblades, the court concluded that G. L. c. 269, § 10 (b), violated the Second Amendment. The court reversed the denial of Canjura's motion to dismiss, vacated his admission to sufficient facts, and ordered judgment to enter for the defendant on the dangerous weapon charge. View "Commonwealth v. Canjura" on Justia Law
Posted in:
Constitutional Law, Criminal Law
Commonwealth v. Lacrosse
The defendant was convicted of first-degree murder for the stabbing death of his ex-girlfriend, Kathryn Mauke. The defendant and the victim had dated on and off for several years, but the victim ended the relationship in December 2014. On February 11, 2015, the defendant left work early, walked to the victim's home, and stabbed her thirty-two times. The defendant's primary defense at trial was that he was not criminally responsible due to mental illness, which the jury rejected.The case was initially tried in the Superior Court, where the defendant was found guilty of first-degree murder on theories of deliberate premeditation and extreme atrocity or cruelty. The defendant filed a motion for a new trial, arguing that the testimony of two incarcerated informants was unreliable and that his trial counsel was ineffective. The motion was denied by the same judge who presided over the trial. The defendant then appealed both his conviction and the denial of his motion for a new trial.The Supreme Judicial Court of Massachusetts reviewed the case. The court held that the testimony of the two incarcerated informants was permissible and declined to create a new rule requiring reliability hearings for such testimony. However, the court mandated supplemental jury instructions for future cases involving incarcerated informants. The court also found that the defendant's trial counsel provided effective assistance and that the prosecutor's statements during closing arguments were proper. The court concluded that the defendant's sentence of life without parole was unconstitutional based on a recent decision, Commonwealth v. Mattis, and modified the sentence to allow for parole eligibility after thirty years. The court affirmed the conviction and the denial of the motion for a new trial. View "Commonwealth v. Lacrosse" on Justia Law
Posted in:
Constitutional Law, Criminal Law
Commonwealth v. Bellard
The defendant was charged with assault and battery on a family or household member and was detained pretrial. While awaiting trial, he made two recorded phone calls to his fiancée, the alleged victim, advising her not to cooperate with authorities. He suggested that if she did not testify, the case against him would weaken. The fiancée expressed concerns about losing her housing and custody of her children due to police and Department of Children and Families (DCF) involvement. The defendant reassured her that things would improve if she followed his advice.The case was initially heard in the Lynn Division of the District Court Department, where the defendant was found guilty of witness intimidation under G. L. c. 268, § 13B. The judge denied the defendant's motion for a required finding of not guilty. The defendant appealed, and the Appeals Court affirmed the conviction. The Supreme Judicial Court of Massachusetts granted further appellate review.The Supreme Judicial Court of Massachusetts reviewed whether the defendant's statements constituted an offer or promise of anything of value to dissuade his fiancée from testifying. The court found that the Commonwealth failed to prove beyond a reasonable doubt that the defendant's vague assurances about their relationship and the potential end of the DCF investigation constituted a bribe. The court noted that the defendant did not have the power to influence the DCF investigation and that his statements did not amount to a quid pro quo arrangement. Consequently, the court reversed the conviction, set aside the finding, and ordered that judgment be entered for the defendant. View "Commonwealth v. Bellard" on Justia Law
Posted in:
Criminal Law
Commonwealth v. Y.
A juvenile was indicted as a youthful offender for unarmed carjacking, unarmed assault with intent to rob, and assault and battery on an elder. The charges stemmed from an incident where the juvenile, after escaping from a secure facility, attacked an elderly man and stole his car. The juvenile pleaded guilty and was sentenced to two years in a house of correction followed by five years of probation.The Juvenile Court initially sentenced the juvenile to a house of correction, but after multiple probation violations, including missing appointments and being involved in new offenses, the court sentenced him to State prison. The juvenile appealed the sentence, arguing it was unlawful and that the judge did not adequately consider his well-being and the impact of recent literature on juvenile brain development.The Supreme Judicial Court of Massachusetts reviewed the case. The court found that the juvenile's sentence was lawful under G. L. c. 119, § 58, which allows for adult sentences, including State prison, for youthful offenders. The court determined that the Juvenile Court judge had appropriately considered the juvenile's criminal history, noncompliance with probation, and the need for public safety. The court also concluded that the judge did not need to make specific written findings on the impact of juvenile brain development literature.Additionally, the Supreme Judicial Court held that the Appellate Division of the Superior Court is authorized to review sentences to State prison imposed by the Juvenile Court on youthful offenders. This ensures that youthful offenders have the same procedural safeguards as adult criminal defendants. The court affirmed the juvenile's sentence and allowed for the appeal to the Appellate Division. View "Commonwealth v. Y." on Justia Law
Commonwealth v. Z.
The juvenile in this case was on probation after being adjudicated as a youthful offender for breaking and entering a vehicle with intent to commit a felony. While on probation, he began experiencing severe mental health issues, including hallucinations and delusions, which led him to obtain a firearm illegally. His mother called the police, and he was found in possession of a loaded firearm without a license. This led to new criminal charges and a notice of probation violation for not obeying state laws.The Juvenile Court judge found that the juvenile violated his probation by possessing the firearm and revoked his probation, sentencing him to incarceration. The judge ruled that the defense of lack of criminal responsibility was not available in probation violation hearings but considered the juvenile's mental illness in determining the disposition. The juvenile appealed, arguing that due process requires allowing the defense of lack of criminal responsibility in probation violation hearings.The Supreme Judicial Court of Massachusetts reviewed the case and held that the affirmative defense of lack of criminal responsibility is not required in probation violation hearings. The court reasoned that the primary inquiry in such hearings is whether the probationer violated a condition of probation, not whether the probationer is criminally responsible. However, the court acknowledged that evidence of mental illness is relevant to determining whether a violation was willful and in deciding the appropriate disposition. The court affirmed the lower court's decision, finding no error in the judge's ruling or abuse of discretion in revoking the juvenile's probation and imposing a sentence of incarceration. View "Commonwealth v. Z." on Justia Law
Commonwealth v. Baez
The defendant was convicted of murder in the first degree, armed assault with intent to murder, and assault and battery by means of a dangerous weapon. The charges stemmed from his role as the getaway driver after a shooting in Charlestown, Boston, where two men in hooded sweatshirts shot Ryan Morrissey and Jamie Lawton outside a convenience store, killing Morrissey and seriously injuring Lawton. Witnesses saw the assailants flee on foot and enter a car driven by the defendant. The car was later identified as belonging to the defendant's mother.In the Superior Court, the defendant was tried jointly with two alleged assailants, Danilo Soto and Alexander Soto, who were acquitted by the jury. The defendant was found guilty on all charges. He appealed, arguing insufficient evidence to prove he was the driver and that he shared the assailants' lethal intent. He also challenged the trial judge's decisions on jury selection and the admissibility of expert testimony.The Supreme Judicial Court of Massachusetts reviewed the case. The court found sufficient evidence to establish that the defendant was the getaway driver. However, it concluded that there was insufficient evidence to prove that the defendant knew of or shared the assailants' lethal intent. The court emphasized that the evidence did not show the defendant knew the assailants were armed or intended to kill the victims. Consequently, the court reversed the defendant's convictions of murder in the first degree, armed assault with intent to murder, and assault and battery by means of a dangerous weapon, and remanded the case for entry of a required finding of not guilty. View "Commonwealth v. Baez" on Justia Law
Posted in:
Criminal Law