Justia Massachusetts Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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In this case, six plaintiffs -- two criminal defense organizations, two defense attorneys, and two former criminal defendants -- filed a petition against the District Attorney's Office for the Hampden District in Massachusetts. The plaintiffs alleged multiple failures by the District Attorney's Office, primarily stemming from its handling of evidence of misconduct within the Springfield Police Department (the department). The U.S. Department of Justice had previously conducted an investigation and found that officers in the department, particularly those within the narcotics bureau, routinely falsified police reports and engaged in a pattern of excessive force.The Supreme Judicial Court of Massachusetts found that the District Attorney's Office, through certain discovery policies, committed a breach of both the duty to disclose evidence that tends to exculpate defendants and the duty to investigate or inquire about such evidence. Specifically, the court identified three problematic practices: 1) disclosing adverse credibility findings made about the department's officers only on a discretionary basis; 2) withholding instances of officer misconduct from disclosure where a specific bad act cannot be clearly attributed to a particular officer; and 3) failing to gain access to all documents known to have been reviewed by the Department of Justice (DOJ).To rectify these breaches, the court ordered the District Attorney's Office to obtain access to all categories of documents known to have been reviewed by the DOJ and disclose them to the plaintiffs. From there, case-by-case adjudication can begin to address the claims of individual defendants affected by the department's misconduct. In issuing this order, the court emphasized the importance of a prosecutor's dual duties -- to disclose and to investigate -- in upholding the integrity of the criminal justice system. View "Graham v. District Attorney for the Hampden District" on Justia Law

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In a case before the Supreme Judicial Court of Massachusetts, the defendant, Denzel McFarlane, convicted of unlawful possession of a firearm and other related charges, appealed for a new trial. He based his appeal on the fact that a police officer who had arrested and testified against him was found civilly liable for false arrest and false imprisonment in an unrelated lawsuit. McFarlane argued that the existence of the civil lawsuit against the officer was exculpatory information that the prosecution should have disclosed to the defense but failed to do so.The primary legal issue was whether the existence of a pending civil lawsuit against a police officer must be disclosed by a prosecutor as exculpatory evidence. The court held that the existence of a pending civil lawsuit against a police officer does not need to be disclosed by a prosecutor as exculpatory evidence. The court reasoned that until a finding of liability has been made, a pending civil lawsuit constitutes an unsubstantiated allegation of police misconduct that does not tend to negate the guilt of the defendant. Therefore, the court affirmed the denial of McFarlane's motion for a new trial.In addition, the court established that while a prosecutor has no duty to inquire into pending civil lawsuits against a prosecution team member, the duty of inquiry does require that prosecutors inquire about the existence of any findings of civil liability related to the performance of a police officer's duties. In other words, if a police officer has been found liable in a civil lawsuit, the prosecution has a duty to discover that information and potentially disclose it to the defense. View "Commonwealth v. Mcfarlane" on Justia Law

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The case involves the Commonwealth's appeal of a judgment by a single justice of the Supreme Judicial Court of Massachusetts, which upheld a lower court judge's decision to disqualify a prosecutor, Matthew Green, from a murder case. The defendant, Blake Scanlon, had been indicted on murder charges and was also later charged with soliciting to commit witness intimidation and murder. One of the solicitation targets was Green, the prosecutor for the initial murder indictment. The basis for Green's disqualification was not because he was a victim in the solicitation case, but because he made himself a potential witness at trial. This was due to his interactions with a jailhouse informant, with whom Scanlon was incarcerated and who claimed Scanlon solicited him for a murder-for-hire plot. In exchange for the informant's cooperation, Green advocated for lighter sentences and bail conditions for him in separate legal proceedings. The defendant argued that these actions made Green a potential witness, either to confirm or dispute the informant's claims, or to question the informant's credibility due to bias in favor of the Commonwealth. The lower court judge agreed and disqualified Green from the case. The Commonwealth appealed, arguing that Green's disqualification was an error, as he was only a potential witness, and that other means could be used to present the necessary information at trial. The Commonwealth also argued that the disqualification raised separation of powers concerns by interfering in the executive branch's discretion to choose a prosecutor. The Supreme Judicial Court disagreed, affirming the lower court judge's decision. It found that the level of Green's involvement with the informant's legal proceedings was extensive, making him more than just a potential witness, and that the judge's decision did not constitute an intolerable interference in the executive branch. View "Commonwealth v. Scanlon" on Justia Law

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In this case, a Superior Court judge in Massachusetts sought guidance from the Supreme Judicial Court on three questions involving the pretrial confinement of a juvenile charged with murder. The juvenile, who was sixteen years old when he was charged with second-degree murder, was initially held without bail at a Department of Youth Services (DYS) facility due to a "courtesy" arrangement with the county sheriff. As the juvenile neared his eighteenth birthday, he was informed that he would be moved to an adult facility. In response, a Superior Court judge released him on personal recognizance on the murder charge and set bail on a related non-murder charge, ordering that he stay at the DYS facility.The Supreme Judicial Court of Massachusetts was asked to determine: 1) whether a Superior Court judge can commit a person under age eighteen charged with murder to DYS's care as a pre-trial detainee; 2) if not, can a Superior Court judge set bail on a charge related to, but other than murder, so that the person under eighteen is not held on bail on the murder charge and is committed to DYS's care; and 3) if the answers to questions 1 and 2 are "No," is the last paragraph of G. L. c. 119, § 68 (which mandates that juveniles charged with murder be committed to the custody of the sheriff) unconstitutional?The Supreme Judicial Court declined to answer the third question due to mootness, as the defendant had since turned eighteen and pleaded guilty to manslaughter. Regarding the first two questions, the court referred to its previous ruling in Nicholas-Taylor v. Commonwealth and affirmed that a Superior Court judge does not have the authority to commit a juvenile defendant charged with murder to the custody of DYS, nor can they sidestep this requirement by committing the juvenile to DYS on a related non-murder offense. Therefore, the answers to the first and second questions were "No." View "Commonwealth v. Padilla" on Justia Law

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In a case before the Supreme Judicial Court of Massachusetts, the defendant, Elvio Marrero, was convicted of the murder of Pernell Kimplin based on evidence that included bloodstains on Marrero's leather jacket. The bloodstains were used by the prosecution to link Marrero to the crime and to support the testimony of a key witness. However, twenty years after the trial, DNA testing showed that the blood on the jacket did not belong to the victim. Marrero's motion for a new trial, based on these DNA test results, was initially denied by a lower court, but the Supreme Judicial Court disagreed with that decision. The court found that the bloodstains were the strongest piece of physical evidence linking Marrero to the murder, and were used by the prosecution to corroborate the testimony of a key witness with credibility issues. As such, the court held that the bloodstains on the jacket likely played a significant role in the jury's deliberations. The court concluded that, had the new DNA test results been available at the time of the trial and the prosecution had been unable to connect the bloodstains to the murder, there is a substantial risk that the outcome of the trial would have been different. Therefore, the court vacated Marrero's conviction and remanded the case for a new trial. View "Commonwealth v. Marrero" on Justia Law

Posted in: Criminal Law
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In this case, the defendant, Jason Robinson, was convicted of first-degree murder on a joint venture theory of felony-murder, with armed robbery as the predicate offence, in connection with the shooting death of Inaam Yazbek. Robinson appealed his convictions and the denial of his motion for a new trial, claiming insufficient evidence and trial errors.The Supreme Judicial Court of Massachusetts affirmed Robinson's conviction of murder in the first degree and the order denying his motion for a new trial. The court held that there was sufficient evidence to convict Robinson of felony-murder, as there was enough to permit an inference that Robinson knew that his co-defendant was armed during the commission of the armed robbery.The court also found no error in the admission of certain evidence, rejected Robinson's claim that he was prejudiced by being tried with his co-defendant, and found no error in the jury instructions, the exclusion of certain third-party culprit and police failure to investigate evidence, or in the prosecutor's opening statement and closing argument.However, the court ruled that Robinson's sentence of life without the possibility of parole was unconstitutional because he was nineteen years old at the time of the offense. The case was remanded for re-sentencing in line with the court's decision in Commonwealth v. Mattis. View "Commonwealth v. Robinson" on Justia Law

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In this Massachusetts case, the defendant, Nyasani Watt, was convicted of first-degree murder and related offenses. After his conviction was affirmed by the Supreme Judicial Court of Massachusetts, he filed a motion for a new trial, alleging that his trial counsel had slept during critical portions of the trial, thus depriving him of his constitutional right to counsel. This motion was denied by a lower court judge without a hearing, and the denial was appealed to the Supreme Judicial Court.The Supreme Judicial Court determined that Watt had presented a new, substantial issue that it could not have considered in its previous review - namely, that his trial counsel had been sleeping during significant parts of the trial.Upon reviewing the evidence, which included affidavits from several people who had observed the trial counsel sleeping, the Court found that the trial counsel did indeed sleep through a significant portion of the trial and possibly during an important aspect of the trial. The Court held that this constituted a constructive deprivation of Watt's right to counsel under Article 12 of the Massachusetts Declaration of Rights.The Court further ruled that this error created a substantial risk of a miscarriage of justice and thus the defendant's convictions were vacated, the verdicts were set aside, and the matter was remanded to the Superior Court for a new trial. View "Commonwealth v. Watt" on Justia Law

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In the case before the Supreme Judicial Court of Massachusetts, the defendant, Sheldon Mattis, was convicted of first degree murder among other charges, and was sentenced to a mandatory term of life in prison without the possibility of parole. At the time of the murder, Mattis was eighteen years old. He appealed his sentence, arguing that it was unconstitutional as applied to him because he was an "emerging adult" (defined in this case as eighteen, nineteen, or twenty years old at the time of the crime), and should be entitled to the same protection as juvenile offenders, who receive a term of life with the possibility of parole.The court considered whether their previous ruling in Diatchenko I, which concluded that sentencing a juvenile to life without parole in any circumstance would violate the Massachusetts Declaration of Rights, should be extended to apply to emerging adults. The court reviewed scientific evidence showing that the brains of emerging adults are not fully mature and are similar to those of juveniles, and also considered the treatment of emerging adults in Massachusetts and elsewhere.The court concluded that a sentence of life without the possibility of parole for emerging adult offenders violates the Massachusetts Declaration of Rights. As a result, the court invalidated the provisions of Massachusetts law that deny the possibility of parole to emerging adults. The court remanded the matter to the lower court for resentencing consistent with the court's opinion. The court also noted that this ruling does not suggest that emerging adults receiving the benefit of resentencing should be paroled once they have served a statutorily designated portion of their sentences. Instead, the parole board should evaluate the circumstances surrounding the commission of the crime, including the age of the offender, together with all relevant information pertaining to the offender's character and actions during the intervening years since conviction. View "Commonwealth v. Mattis" on Justia Law

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In the case at hand, the defendant, Joshua Hart, and his girlfriend, Brittany Smith, entered the home of an elderly couple, Thomas Harty and his wife, Joanna Fisher, intending to steal their car and money. The couple ended up fatally attacking both Harty and Fisher, and then fled the state in the victims' vehicle. Hart was convicted on two counts of first-degree murder, and he appealed on several grounds.Hart argued that his confession to law enforcement was involuntary and should have been suppressed, but the Supreme Judicial Court of Massachusetts disagreed. The court found that Hart's confession was voluntary based on the circumstances of the interrogation, his experience with the criminal justice system, and his own actions and statements during the interrogation.Hart also argued that the trial should have been moved to another venue due to pretrial publicity. The court disagreed, stating that the defendant did not provide sufficient evidence to demonstrate that the pretrial publicity caused either presumptive or actual prejudice. The court found that less than 20% of potential jurors were excused due to pretrial publicity, and the judge took extensive steps to protect Hart's right to a fair trial.Hart further contended that a statement made by the deceased victim, Fisher, to her nurse, which was relayed to the jury through the nurse's testimony, should have been excluded from evidence as it was hearsay and violated his right to confront witnesses. The court determined that Fisher's statements were non-testimonial and thus did not violate the confrontation clause. The court also found that even if Fisher's statements were admitted in error, there was no prejudice because the Commonwealth presented other compelling evidence of the facts relayed in Fisher's statements.Finally, Hart argued that his sentences of life without the possibility of parole constituted cruel or unusual punishment because he was under 25 years old at the time of the crimes. The court rejected this argument, finding no reason to extend the prohibition of life sentences without parole for juveniles to individuals under the age of 25.Accordingly, the court affirmed Hart's convictions. View "Commonwealth v. Hart" on Justia Law

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In the case before the Supreme Judicial Court of Massachusetts, defendant Amadi Sosa was convicted of murder in the first degree, armed assault with the intent to rob, and unlawful possession of ammunition in connection with the shooting death of William Serrano. The defendant appealed his convictions and the denial of his motion for a new trial, alleging several errors, including that the trial judge wrongfully denied his motion for relief from a joint trial with his co-defendant, Julio Brian Leiva, and that the judge erroneously allowed the prosecutor to use an unauthenticated video recording during the trial. The court affirmed the defendant's convictions of murder in the first degree and armed assault with the intent to rob, and the denial of his motion for a new trial. However, the court vacated the defendant's conviction of unlawful possession of ammunition due to an error in the jury instructions. The court found that there was no reversible error with respect to the defendant's convictions of murder in the first degree and armed assault with the intent to rob, and declined to exercise its authority under G. L. c. 278, § 33E to grant relief or order a new trial. View "Commonwealth v. Sosa" on Justia Law

Posted in: Criminal Law