Justia Massachusetts Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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In this case involving procedures and remedies for impermissible peremptory challenges the Supreme Judicial Court adopted the language of the Federal standard for the first step of a challenge pursuant to Batson v. Kentucky, 476 U.S. 79 (1986), and retired the language of "pattern" and "likelihood" governing the first-step inquiry under Commonwealth v. Soares, 444 U.S. 881 (1979).While incarcerated, Defendant argued on appeal and in pursuing postconviction relief that the trial judge did not appropriately inquire as to whether the prosecutor unconstitutionally struck African-American men from the jury. The Appeals Court determined that the trial judge did not err in deciding not to continue past the first step of the Batson-Soares inquiry. In granting Defendant's petition for writ of habeas corpus, the First Circuit concluded that the trial judge unreasonably applied Federal law. Defendant then filed a motion for a new trial or, in the alternative, for a reduced sentence. The motion judge reduced the verdict under Mass. R. Crim. P. 25(b)(2) and resentenced Defendant. The Supreme Judicial Court vacated the order and remanded for retrial, holding (1) the judge improperly reduced the verdict, and the principles of double jeopardy did not preclude retrying Defendant; and (2) adopting the Federal formulation of the Batson-Soares test will better identify improper peremptory challenges. View "Commonwealth v. Sanchez" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on a theory of extreme atrocity or cruelty, holding that there was no error that resulted in a substantial likelihood of a miscarriage of justice.Specifically, the Supreme Court held (1) Defendant's statements that he made to police were properly admitted into evidence; (2) the trial judge did not err in finding that text messages sent after the murder were admissible; (3) the trial judge did not err in admitting a redacted version of the videotaped custodial interrogation of Defendant; (4) the trial judge did not err in declining to instruct the jury on involuntary manslaughter; (5) the trial judge did not err in denying Defendant's postconviction motion for a new trial; and (6) there was no reason to order a new trial or reduce the degree of guilt under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Lopez" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court affirmed Defendant's conviction for murder in the first degree, holding that any claimed instructional errors did not give rise to a substantial likelihood of a miscarriage of justice and that Defendant did not receive ineffective assistance of counsel.On appeal, Defendant argued that the trial court erred by failing to instruct the jury concerning a lack of criminal responsibility and mental impairment and erred by failing properly to instruct the jury that they could consider evidence of intoxication when determining whether a murder was committed with extreme atrocity or cruelty. Defendant further argued that trial court's failure to remedy the instructional errors deprived him of the effective assistance of counsel. The Supreme Judicial Court affirmed, holding (1) there was no error in the jury instructions and, accordingly no substantial likelihood of a miscarriage of justice in counsel's handling of the instructions; and (2) there was no reason to reduce the verdict to one of murder in the second degree. View "Commonwealth v. Santiago" on Justia Law

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The Supreme Judicial Court denied Defendant's motion for attorney's fees and costs made by an attorney who claimed to have been privately retained by Defendant for the purpose of opposing the Commonwealth's application for leave to appeal, holding that no attorney's fees are required under Mass. R. Crim. P. 15(d) in this situation.Defendant, who was indigent, was convicted of murder in the second degree and two firearm offenses. Before trial, Defendant filed motions to suppress a variety of evidence. After the trial judge ruled on the motions, both sides sought leave to appeal from the rulings that were adverse to them. The Supreme Court affirmed in part and reversed in part. At issue was the attorney's fees request by the attorney claiming to be privately retained by Defendant. The Supreme Judicial Court denied the request, holding that Rule 15(d) was not meant for attorneys who represent defendants whom they know to be indigent and from whom they never expect to receive payment. View "Commonwealth v. Vasquez" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court affirmed Defendant's conviction for murder in the first degree on a theory of extreme atrocity or cruelty, holding that the errors that occurred during the trial did not require a new trial.On appeal, Defendant argued that she was prejudiced from the Commonwealth's use of prior bad act evidence. The Supreme Judicial Court affirmed, holding (1) some of the challenged evidence should not have been admitted, but there was no abuse of discretion int he judge's conclusion that the probative value of the evidence was not outweighed by its prejudicial effect; (2) the prosecutor's reliance on the prior bad act evidence in closing arguments was improper, but the improprieties did not so infuse the trial with unfairness as to deny due process of law; and (3) a reduction in the verdict pursuant to Mass. Gen. Laws ch. 278, 33E would not serve the interests of justice. View "Commonwealth v. Peno" on Justia Law

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The Supreme Judicial Court reversed the denial of the motions to suppress filed by Nelson Mora and Ricky Suarez, holding that the continuous, long-term pole camera surveillance targeted at the residences of Mora and Suarez was a search under article 14 of the Massachusetts Declaration of Rights.Using video footage collected by hidden video cameras on public telephone and electrical poles (pole cameras) the Commonwealth secured indictments against twelve defendants, including Mora and Suarez. Eight defendants moved to suppress the pole camera footage and evidence derived from that footage as the fruits of an unreasonable search. The superior court denied the motions, concluding that the pole camera surveillance did not constitute a search. The Supreme Judicial Court reversed as to Mora and Suarez and remanded the matter to the superior court for further proceedings, holding that the warrantless surveillance of Mora's and Suarez's residences for more than two months was a "search" under article 14. View "Commonwealth v. Mora" on Justia Law

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The Supreme Judicial Court reversed the order of the superior court judge allowing Defendant's motion to suppress statements he made to police officers, holding that Defendant was not subjected to custodial interrogation while speaking with the police officers and that the statements were otherwise voluntary.Defendant was placed under arrest for the removal of human remains from the Worcester cemetery. Defendant filed a motion to suppress statements he made to Hartford police officers, arguing that the statements were made under custodial interrogation without Miranda warnings and that they were involuntary. The motion judge allowed the motion to suppress. The Supreme Judicial Court reversed, holding (1) Defendant was not in custody when he made his statements to the police officers, and therefore, Miranda warnings were not required; and (2) there was no indication that Defendant's statements were involuntarily made. View "Commonwealth v. Medina" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction for murder in the first degree, holding that there was no prejudicial error in the proceedings below, and there was no reason for the Court to exercise its authority under Mass. Gen. Laws ch. 278, 33E to reduce the verdict or to order a new trial.Specifically, the Supreme Judicial Court held (1) the motion judge did not err in denying Defendant's motion to suppress his statement to the police; (2) an indisputably gruesome photograph should not have been admitted into evidence, but there was no cause to disturb the verdict; (3) there was no error in the absence of a sua sponte instruction on lost evidence; (4) the judge did not err in admitting into evidence two knives; (5) certain statements in the prosecutor's closing argument were improper, but the improprieties did not require a new trial; and (6) there were no grounds on which to reduce the degree of guilt or to order a new trial. View "Commonwealth v. Walters" on Justia Law

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The Supreme Judicial Court affirmed Defendant's convictions for murder in the first degree and assault and battery and several related orders denying postconviction relief, holding that each of Defendant's claims lacked merit.Specifically, the Supreme Judicial Court held (1) the trial court did not err in denying Defendant's pretrial motion to suppress digital camera images; and (2) the Commonwealth violated its obligation under article 36 of the Vienna Convention on Consular Relations to apprise Defendant of his article 36 rights to representation of counsel of his choice and court-appointed conflict-free counsel, but the error was neither constitutional nor structural. View "Commonwealth v. Fernandes" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court vacated Defendant's conviction for kidnapping but affirmed all other convictions, holding that the verdicts of murder in the first degree were consonant with justice but that Defendant's kidnapping conviction must be vacated because it was based on an inveiglement theory previously dismissed by the motion judge.Defendant was found guilty of three counts of murder in the first degree, kidnapping, and witness intimidation. On appeal, Defendant argued, among other things, that his conviction of kidnapping based on a 2010 incident must be vacated because the theory of kidnapping was invalid or foreclosed by the superior court judge's ruling on a pretrial motion to dismiss. The Supreme Judicial Court agreed, holding (1) Defendant's 2010 kidnapping conviction must be reversed, as the theory on which the prosecution proceeded at trial had previously been dismissed by the court; (2) Defendant was not entitled to relief on his remaining allegations of error; and (3) there is no reason for this Court to exercise its authority under Mass. Gen. Laws ch. 278, 33E to order a new trial or direct the entry of verdicts of a lesser degree of guilt. View "Commonwealth v. Hall" on Justia Law