Justia Massachusetts Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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The Supreme Judicial Court affirmed the judgment of the county court denying Defendant's petition for relief under Mass. Gen. Laws ch. 211, 3, holding that the single justice neither erred nor abused his discretion in denying relief. Defendant was indicted on charges of murder in the first degree and other offenses. The trial judge declared a mistrial because the jury were unable to reach a verdict on the murder charge. Defendant moved to dismiss the murder indictment and for a required finding of not guilty, arguing that a retrial was barred by double jeopardy principles because there was insufficient evidence to warrant a conviction. The trial court denied the motion. Defendant then filed a Mass. Gen. Laws ch. 211, 3 petition seeking relief from the denial of that motion. The single justice denied relief. The Supreme Judicial Court affirmed, holding that double jeopardy principles did not bar Defendant's retrial on the murder charge because the Commonwealth presented sufficient evidence to warrant a conviction of murder in the first degree based on extreme atrocity or cruelty. View "Collazo v. Commonwealth" on Justia Law

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The Supreme Judicial Court reversed the order of the motion judge denying Defendant's motion to suppress evidence found in his motor vehicle following a search, holding that the exit order that precipitated the search of the vehicle was unjustified. A search of a box hidden inside the front passenger seat of the vehicle at issue revealed a large amount of cocaine and several large stacks of cash. Defendant was subsequently charged with trafficking in cocaine. Defendant moved to suppress the evidence, arguing that the search took place after an unlawful exit order. The superior court denied Defendant's motion to suppress. The Supreme Judicial Court reversed, holding that because the exit order was not lawfully issued the evidence obtained from the subsequent search should have been suppressed as fruit of the poisonous tree. View "Commonwealth v. Barreto" on Justia Law

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The Supreme Judicial Court affirmed Defendant's convictions and the denial of his postconviction motions and declined to grant extraordinary relief pursuant to Mass. Gen. Laws ch. 278, 33E, holding that any error in the proceedings below was harmless. Defendant was convicted of murder in the first degree on the theory of deliberate premeditation and related charges. Before the Supreme Judicial Court was Defendant's appeal from his convictions, from the denial of his motion for a new trial, and from the denial of a motion to reconsider the denial of his new trial motion. The Supreme Judicial Court affirmed, holding (1) Defendant was not entitled to relief on his argument that newly discovered medical records warranted a new trial; (2) trial counsel was not constitutionally ineffective; (3) that the trial judge did not commit reversible error in admitting evidence of the defendant's prior, failed attempts to purchase a firearm; and (4) there was no reason for this Court to exercise its authority under Mass. Gen. Laws ch. 278, 33E to grant a new trial or to reduce or set aside the jury's verdict of murder in the first degree. View "Commonwealth v. Don" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction and the denials of Defendant's two motions for a new trial and declined to grant extraordinary relief pursuant to Mass. Gen. Laws ch. 278, 33E, holding that there was no error in the proceedings below. Specifically, the Court held (1) the trial court did not err by denying Defendant's motion for a required finding of not guilty; (2) Defendant did not receive ineffective assistance of counsel; (3) the trial judge did not err in admitting allegedly unduly prejudicial evidence, failing to sanction the Commonwealth for the alleged destruction of exculpatory evidence, and failing to recuse herself; and (4) because there was no error, any allegations of unpreserved cumulative error were without merit. View "Commonwealth v. Norris" on Justia Law

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The Supreme Judicial Court affirmed Defendant's convictions of murder in the first degree and conspiracy to commit murder and declined to grant extraordinary relief under Mass. Gen. Laws ch. 278, 33E, holding that the trial judge did not abuse her discretion in admitting certain prior consistent statements and that there was no reason to grant a new trial or to reduce the verdict. A jury convicted Defendant of murder in the first degree on the theories of deliberate premeditation and extreme atrocity or cruelty and of conspiracy to commit murder. Defendant appealed, arguing that the trial judge abused her discretion by allowing a State police trooper to testify to the prior statements of a key witness that were consistent with that witness's trial testimony. The Supreme Judicial Court affirmed and declined to exercise its authority to reduce the verdict or order a new trial, holding there was no error in the admission of the prior consistent statements. View "Commonwealth v. Morales" on Justia Law

Posted in: Criminal Law
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In this postconviction action arising from the misconduct of chemist Annie Dookhan at the William A. Hinton State Laboratory Institute the Supreme Judicial Court affirmed the order of the postconviction court denying Defendant postconviction relief, holding that Defendants who withdrew their guilty pleas after Dookhan's misconduct was discovered but before the Court's decision in Bridgman v. District Attorney for the Suffolk District, 471 Mass. 465 (2015), are entitled retroactively to the protection of the Bridgeman sentencing cap but only if they actually were convicted of more serious charges or received a more severe sentence than at their first plea. Defendant successfully moved to withdraw his guilty plea to trafficking cocaine on the ground that Dookhan's misconduct rendered his plea involuntary. Defendant then pleaded guilty to possession with intent to distribute. After Bridgeman was decided Defendant moved to withdraw his second guilty plea. The motion was denied. The Supreme Judicial Court affirmed, holding that where Defendant negotiated his second plea agreement in the shadow of the original charges but was not convicted of more severe charges and did not receive a harsher punishment there was no violation of the principles underlying the Bridgeman sentencing cap and thus no need for a third plea or trial in order to apply Bridgeman retroactively. View "Commonwealth v. Camacho" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court affirmed the judgment of the single justice denying Petitioner's petition pursuant to Mass. Gen. Laws ch. 211, 3, in which Petitioner sought a stay of execution of sentence pending appeal, holding that Petitioner had an adequate alternative remedy. Petitioner was convicted of numerous counts of unlawful possession of a large capacity feeding device and other crimes. After he was sentenced, Petitioner filed a petition in the county court seeking to stay the execution of sentence. The single justice denied the petition. The Supreme Judicial Court affirmed, holding that the single justice did not err or abuse her discretion in denying relief because Petitioner had an adequate alternative remedy. View "Goodwin v. Commonwealth" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court vacated Defendant's conviction of murder in the first degree and remanded the case, holding that errors in the closing argument constituted a miscarriage of justice requiring that Defendant's conviction not stand. After Defendant was convicted of murder in the first degree the Supreme Judicial Court remanded the matter to the superior court, where the Commonwealth was given a choice of either vacating the conviction and retrying Defendant on the murder indictment or accepting a reduction of the verdict to manslaughter. The Commonwealth chose to pursue a new trial. After the trial, the jury again convicted Defendant of murder in the first degree. The Supreme Judicial Court again remanded the matter to the trial court, where the Commonwealth again may accept a reduction in the verdict or manslaughter or retry Defendant on the murder charge, holding that errors in the closing argument that were reprised from the first trial and newly introduced required a new trial, and this determination was reinforced by other issues that emerged on the Court's review pursuant to Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Niemic" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction of armed robbery, holding that the motion judge did not err in denying Defendant's motion to suppress evidence of a showup identification but that, for showup identification procedures going forward, the officers conducting the showup will be required to provide instructions similar to those used in identifications through photographic arrays. In his appeal, Defendant argued (1) the showup identification evidence should have been suppressed because the procedure was so unnecessarily suggestive and conducive to mistaken identification that it denied him due process of law, and (2) the trial judge erred on several evidentiary rulings on eyewitness identification. The Supreme Judicial Court affirmed, holding (1) there was no abuse of discretion in the trial judge's determination that the identification procedure in this case was not unnecessarily suggestive; (2) following issuance of the prescript in this case, police are required to provide witnesses with an instruction prior to showup identification similar to those used in identifications through photographic arrays; and (3) there was no reversible error in the trial judge's evidentiary rulings on eyewitness identification. View "Commonwealth v. German" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court affirmed the judgment of the county court denying Petitioner's petition for relief under Mass. Gen. Laws ch. 211, 3, holding that where Petitioner had ordinary means to challenge her sentence the single justice did not err or abuse her discretion by denying extraordinary relief. Petitioner was convicted of making false Medicaid claims and of larceny by false pretenses. Before sentencing, Petitioner filed a motion requesting that the judge consider the provisions of Mass. Gen. Laws ch. 279, 6B. Petitioner was sentenced to a term of incarceration. In her Mass. Gen. Laws ch. 211, 3 petition, Petitioner argued that the judge violated section 6B by sentencing her to a term of incarceration without making the necessary findings. The single justice denied relief on the ground that Petitioner had an adequate alternative remedy. The Supreme Judicial Court affirmed, holding that Petitioner had a remedy in the ordinary appellate process. View "Kiago-Wilson v. Commonwealth" on Justia Law

Posted in: Criminal Law