Justia Massachusetts Supreme Court Opinion Summaries

The case revolves around Quasim Hastings, a prisoner convicted of second-degree murder in 2004 and eligible for parole consideration. Hastings, diagnosed with a mental disability, is entitled to a parole hearing that provides him with protections under the Massachusetts Constitution and Federal and State statutes prohibiting discrimination based on disability. Prior to a 2023 parole hearing, Hastings' counsel filed a motion for funds to retain a forensic psychologist and a social services advocate to assist with preparing a prerelease plan. While the motion for a forensic psychologist was approved, the request for a social services advocate was denied by a different Superior Court judge, who reasoned that the indigency statute limits his authority to approve funds to pending proceedings or appeals in any court.The judge's denial of the motion for funds was reported to the Appeals Court, and Hastings's application for direct appellate review was granted by the Supreme Judicial Court. The Supreme Judicial Court concluded that Hastings's motion for funds to retain a social services advocate implicates his State constitutional right to reasonable disability accommodations. Therefore, the constitutionally mandated exception to the indigency statute applies, and the order denying Hastings's motion for funds was reversed. The court held that a judge has the discretion to allow a motion for funds to pay for expert assistance as reasonably necessary to safeguard the indigent prisoner's constitutional rights prohibiting discrimination on the basis of disability. View "Commonwealth v. Hastings" on Justia Law

The defendant, Warren W. Dunn, was charged with two counts of possession of child pornography and two counts of possession of child pornography as a subsequent offense. The charges were based on evidence found in his apartment during a search conducted under a warrant. The warrant was issued based on an affidavit by a state trooper, who had received a report from the National Center for Missing and Exploited Children (NCMEC) about two images flagged as potential child pornography by Microsoft. The trooper described the images in his affidavit but did not attach them. The defendant had previously been arrested in 2007 for possession of child pornography.In the Superior Court, the defendant filed motions to suppress the evidence and for a hearing on the affidavit supporting the search warrant. The court denied both motions. The defendant then pleaded guilty to all charges, preserving his right to appeal the denials of his motions.The Supreme Judicial Court of Massachusetts affirmed the lower court's decisions. The court held that, although attaching the photographs or providing a more detailed description would have been preferable, the affidavit as a whole was sufficient to establish probable cause for the search warrant. The court also held that the motion judge did not abuse her discretion in concluding that the defendant failed to demonstrate that the trooper's descriptions of the images were false. The court declined to create a new rule requiring magistrates to personally view allegedly lewd images before issuing search warrants. View "Commonwealth v. Dunn" on Justia Law

The case involves a juvenile who was apprehended with firearms and ammunition and charged with various offenses. After being arraigned as a youthful offender, the juvenile was diagnosed with several information-processing disorders, including a language-based learning disorder. The juvenile was found incompetent to stand trial but capable of attaining competency in the future. However, after two competency proceedings, the juvenile was again found incompetent to stand trial, and the judge declined to make a definite finding on whether the juvenile could attain competency in the foreseeable future. The juvenile filed motions to dismiss the charges under the statute governing the dismissal of pending charges against incompetent persons, but these motions were denied.The Supreme Judicial Court of Massachusetts was tasked with deciding three main issues. First, whether the mental health code provides for the remediation of incompetent juveniles, particularly those incompetent but not mentally ill. Second, whether, in the absence of remediation programming under the mental health code, the ability to create and mandate remediation programming is within the scope of the Juvenile Court's inherent authority. Lastly, whether the pending charges against the juvenile can be dismissed "in the interest of justice."The court held that the mental health code does not provide for the remediation of juveniles found incompetent for reasons other than mental illness. It also rejected the argument that the ability to create and mandate remediation programming for incompetent juveniles falls within the purview of the Juvenile Court's inherent authority, stating that the creation of remediation programming falls within the purview of the Legislature. Regarding the dismissal of charges, the court remanded the matter to the Juvenile Court for further findings on whether the juvenile poses a present danger to the community. View "Makis M. v. Commonwealth" on Justia Law

The case involves a professional photographer who sexually exploited a minor. The defendant initially contacted the victim through a social networking site and began communicating with her through various means, eventually soliciting and receiving explicit images of the victim. The defendant also met the victim in person and sexually abused her. After the victim's parents reported the exploitation to the police, an investigation was launched. The police seized a computer tower, an external hard drive, and other items from the defendant's former residence. A forensic examination of the hard drives revealed explicit images of the victim, communications between the defendant and the victim, and hundreds of images of unidentified females in various stages of undress.The defendant was indicted on multiple counts, including aggravated rape of a child and enticement of a minor. He pleaded guilty to all charges, except for the eight counts of aggravated rape of a child, where he pleaded guilty to the lesser included offense of statutory rape. After being sentenced, the defendant filed a motion for the return of the seized property. The Commonwealth opposed the return of the property, arguing that it was in the "public interest" to destroy the devices. The Superior Court denied the defendant's request for the return of certain property.The Supreme Judicial Court of Massachusetts granted an application for direct appellate review. The court concluded that the procedural requirements set forth in G. L. c. 276, §§ 4 to 8, must be followed before a forfeiture decree may be issued under G. L. c. 276, § 3. The court vacated the Superior Court orders denying the return of certain property to the defendant and remanded the case for further proceedings consistent with its opinion. View "Commonwealth v. James" on Justia Law

In 2005, Leon Robinson was convicted of first-degree murder and unlawful possession of a firearm for the 2001 shooting death of Recardo Robinson. The incident occurred in a barbershop after an argument between the two men. Several witnesses identified Leon as the shooter. The prosecution also presented evidence of a small bloodstain on Leon's jacket that matched the victim's DNA. Leon appealed his convictions and the denial of his motion for a new trial, arguing that evidence obtained from his apartment was wrongly admitted, his right to self-representation was violated, the prosecutor acted improperly, and his counsel was ineffective.The Superior Court Department had previously denied Leon's pretrial motion to suppress evidence from his apartment. Leon argued that the search warrant was erroneously granted, but the Supreme Judicial Court disagreed, finding that the warrant was supported by probable cause. Leon's motion for a new trial was also denied by the Superior Court Department. He argued that his trial counsel was ineffective for not introducing certain evidence and not retaining expert witnesses, but the Supreme Judicial Court found these decisions to be strategic and not manifestly unreasonable.The Supreme Judicial Court affirmed Leon's murder conviction, finding no errors that would have influenced the jury's decision. However, the court vacated his conviction for unlawful possession of a firearm. The court ruled that, in light of a recent U.S. Supreme Court decision, the absence of a license was an essential element of the firearm possession offense that the prosecution needed to prove. The case was remanded for a new trial on the firearm charge. View "Commonwealth v. Robinson" on Justia Law

The case involves Terrence Tyler, who was convicted of felony-murder in the first degree with the predicate felony of attempted unarmed robbery and assault with intent to rob. The incident occurred during a planned robbery of a marijuana dealer, Wilner Parisse, who was shot and killed during a physical altercation. Tyler appealed his conviction and filed two motions for a new trial. The first motion argued that his trial counsel was ineffective for not requesting an involuntary manslaughter jury instruction. The second motion requested the retroactive application of a court decision (Commonwealth v. Brown) that abolished felony-murder as an independent theory of liability for murder. Both motions were denied.The Supreme Judicial Court of Massachusetts reviewed Tyler's case and his motions for a new trial. The court held that the rule in Brown was intended to apply prospectively, and there was no reason to depart from that limitation. The court also found that Tyler's trial counsel did not err by failing to request an involuntary manslaughter instruction, as the pre-Brown default rule applies here. The court further held that the trial judge's instruction did not allow the jury to find Tyler guilty of felony-murder for conduct only sufficient to convict him of manslaughter. The court declined to reduce the verdict of murder in the first degree to a lesser degree of guilt. Therefore, Tyler's conviction was affirmed, and the orders denying his motions for a new trial were also affirmed. View "Commonwealth v. Tyler" on Justia Law

The Supreme Judicial Court of Massachusetts heard an appeal involving Bradley Zucchino, who was charged with operating a motor vehicle under the influence of alcohol, causing serious bodily injury and death. Zucchino challenged the admissibility of his blood alcohol content (BAC) evidence, arguing that it was collected without his consent, contravening G. L. c. 90, § 24 (1) (e). The court had to determine whether the Commonwealth needed the defendant's consent to admit his BAC results in the prosecution of a G. L. c. 90, § 24L (OUI-SBI) offense.The court determined that the language of G. L. c. 90, § 24 (1) (e) was clear and unambiguous, applying specifically to violations of § 24 (1) (a), or simple OUI. The court noted that if the Legislature had intended the consent requirement of § 24 (1) (e) to apply to aggravated OUI offenses, it would have made this explicit. The court stated that it is within the Legislature's purview to treat simple OUI and aggravated OUI offenses differently, including with regard to the admissibility of evidence.Therefore, the Supreme Judicial Court of Massachusetts held that the consent provision of § 24 (1) (e) does not apply to violations under any other section or chapter, including G. L. c. 265, § 13 1/2, or G. L. c. 90, § 24L. The court affirmed the lower court's denial of Zucchino's motion to suppress his BAC results. View "Commonwealth v. Zucchino" on Justia Law

Charles Robinson, the defendant, was convicted of first-degree murder in connection with the shooting death of Edward Figueroa. Following his conviction, Robinson appealed and also filed a motion for a new trial citing multiple errors by trial counsel. Despite his appeal and the motion for a new trial, the conviction was affirmed.Later, Robinson appealed from the denial of his motion for a new trial, arguing that he was not competent to stand trial due to mental health issues and that he had received ineffective assistance of counsel. However, the court upheld the ruling, stating that Robinson had not shown any evidence that his mental health issues had influenced the jury's conclusion or prevented an adequate defense.Robinson's contention that his counsel failed "reasonably to communicate with him" during and after a conversation in the lockup was also dismissed, as the court found no evidence of a breakdown in the attorney-client relationship that warranted a new trial.The court concluded that the defendant did not present a substantial issue meriting an evidentiary hearing and dismissed his request for relief under G. L. c. 278, § 33E for a new trial. View "Commonwealth v. Robinson" on Justia Law

In this case, the defendant, Rigoberto Escobar, was found guilty of first-degree murder for the shooting death of Magno Sosa after a heated argument that escalated into a fistfight. The defendant appealed, arguing that his confession to police was improperly obtained because he was improperly Mirandized, coerced into confessing, and his rights to prompt arraignment and telephone use after arrest were violated. Moreover, the defendant contended that the trial judge made errors by denying his motion for a mistrial and failing to instruct the jury on voluntary and involuntary manslaughter. He also claimed that improper testimony by the Commonwealth's experts on fingerprint identification and forensic ballistics led to a substantial likelihood of a miscarriage of justice. Lastly, the defendant argued that his firearm convictions should be vacated according to a recent ruling in Commonwealth v. Guardado.The Supreme Judicial Court of Massachusetts affirmed the defendant's conviction of murder in the first degree. They concluded that the defendant's motion to suppress his confession was properly denied, his motion for a mistrial was rightly denied, and the trial judge did not err in declining to provide a jury instruction on involuntary manslaughter. However, the trial judge did err in declining to instruct the jury on voluntary manslaughter. Despite this, they found the defendant was not prejudiced by this decision due to the jury instructions as a whole and the lack of evidence supporting a finding of voluntary manslaughter.The court also affirmed that even if the expert testimony was improper, it did not create a substantial likelihood of a miscarriage of justice because the Commonwealth presented overwhelming evidence tying the defendant to the firearm and to the crime. However, the court vacated the defendant's firearm convictions and remanded for a new trial to give the Commonwealth the opportunity to prove that the defendant was not licensed to carry a firearm. View "Commonwealth v. Escobar" on Justia Law

This case involved defendant Julie A. Corey who was convicted of first-degree murder on the grounds of deliberate premeditation, extreme atrocity or cruelty, and felony-murder with the underlying felony of aggravated kidnapping. Following her conviction, Corey filed a motion for a new trial, arguing that she received ineffective assistance of counsel due to her attorney's failure to call a cell phone expert to testify about her location on the night of the murder. She also requested that the court enter a required finding of not guilty. The trial judge, who was also the motion judge, denied Corey's motion for a new trial but vacated her conviction of murder in the first degree on a theory of felony-murder, finding that the evidence was insufficient to prove that Corey committed the predicate felony of aggravated kidnapping.On appeal, the Supreme Judicial Court disagreed with Corey’s argument that she received ineffective assistance of counsel. The court found that her trial counsel's decision not to call a cell phone expert was not ineffective and would not have likely influenced the jury's conclusions. Furthermore, the court agreed with the Commonwealth that there was sufficient evidence to find Corey guilty of felony-murder with a predicate felony of aggravated kidnapping. Consequently, the court reinstated that conviction. The court also declined to exercise its powers under G. L. c. 278, § 33E to reduce Corey's conviction. View "Commonwealth v. Corey" on Justia Law