Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed the superior court judge denying Defendant's motion to suppress a video recording Defendant published to his social media account that showed an individual seen from the chest down holding what appeared to be a firearm, holding that no search in the constitutional sense occurred.After accepting a friend request from an undercover police officer, Defendant published the video at issue to his social media account. The officer made a recording of the posting, and that recording was used in the criminal proceedings against Defendant. The trial judge concluded that no search had occurred and denied Defendant's motion to suppress. The Supreme Court affirmed, holding that Defendant did not retain a reasonable expectation of privacy in his social media stories. View "Commonwealth v. Carrasquillo" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction for two counts of armed assault with intent to murder and other crimes, holding that denying superior court defendants the statutory right to a defendant-capped plea does not violate equal protection principles under either the Federal or State Constitutions.Defendant was charged, pleaded guilty, and was sentenced in the superior court. Defendant sought to withdraw his plea on the basis of a facial challenge to the procedural scheme laid out in Mass. Gen. Laws ch. 278, 18 and rule 12(c)(4)(A), arguing that denying superior court defendants the statutory right to a defendant-capped plea violates constitutional equal protection principles. The Supreme Judicial Court affirmed, holding that the procedural scheme of Mass. Gen. Laws ch. 278, 18 and Mass. R. Crim. P. 12 survives rational basis scrutiny. View "Commonwealth v. Roman" on Justia Law

The Supreme Court vacated and set aside the order of expungement in this case, holding that a judge ordering expungement under Mass. Gen. Laws ch. 276, 100K must employ a two-part procedure.At issue was whether a judge ordering expungement under Mass. Gen. Laws ch. 276, 100K(a) may expunge a record solely because doing so is in the best interests of justice pursuant to Mass. Gen. Laws ch. 276, 100K(b) and thus skip the conditions enumerated in section 100K(a). The judge in this case issued an order allowing Petitioner's petition for expungement. The Supreme Court vacated and set aside the order and remanded the matter for further proceedings, holding (1) a judge ordering expungement must make findings based on clear and convincing evidence that the relevant criminal record was created because of one or more of the reasons listed in section 100K(a); and (2) after making such findings a judge may consider whether expungement would be in "the best interests of justice" under section 100K(b). View "In re Expungement" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction for murder in the first degree on theories of deliberate premeditation and extreme atrocity or cruelty and the denial of his motion for a new trial, holding that there was no prejudicial error or reason to grant relief under Mass. Gen. Laws ch. 278, 33E.In his motion for a new trial, Defendant asserted that he located a newly available witness who would provide impeachment evidence against one of the Commonwealth's key witnesses. The motion judge denied the motion. Defendant appealed, arguing, among other things, that the judge erred in allowing the admission of certain testimony, and that the judge erroneously denied his request for a continuance and motion for a new trial. The Supreme Judicial Court affirmed Defendant's convictions and the denial of his motion for a new trial, holding that Defendant was not entitled to relief on his allegations of error. View "Commonwealth v. Gibson" on Justia Law

The Supreme Judicial Court affirmed the judgment of a single justice of the court denying Petitioner's petition pursuant to Mass. Gen. Laws ch. 211, 3, holding that the single justice did not err or abuse his discretion in denying relief.Petitioner was charged with several offenses and was held on a finding of dangerousness. The Commonwealth later requested that Petitioner's detention remain in effect, arguing that the entire period of Petitioner's detention up to that point was excludable. The judge maintained Petitioner's detention. Petitioner then brought this petition. The single justice denied relief. The Supreme Judicial Court affirmed, holding that there was no error or abuse of discretion in the denial of relief. View "David v. Commonwealth" on Justia Law

The Supreme Judicial Court affirmed the judgment of the single justice denying Defendant's petition for relief under Mass. Gen. Laws ch. 211, 3, holding that the decision in Donavan v. Commonwealth, 426 Mass. 13 (1997), is still good law.Defendant was charged with operating a motor vehicle while under the influence of alcohol. Defendant moved for a mistrial during closing arguments and again after the jury returned a guilty verdict on the basis of prosecutorial misconduct. The motion was denied but the judge granted Defendant's alternative motion for a new trial. Defendant filed a motion to dismiss the charge on double jeopardy grounds, which the judge denied. Defendant then brought this petition for relief. The single justice denied the petition. The Supreme Judicial Court affirmed, holding (1) this Court declines to reconsider its holding in Donavan; and (2) Defendant did not present a double jeopardy claim warranting the extraordinary relief of Mass. Gen. Laws ch. 211, 3. View "Perrier v. Commonwealth" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of two counts of rape and one count of photographing an unsuspecting nude person, holding that there was no error in the proceedings below.On appeal, Defendant argued that there was insufficient evidence to support the convictions and that the trial court coerced a juror requesting to be dismissed into reaching an unanimous verdict. The Supreme Judicial Court disagreed, holding (1) there was sufficient evidence to support all of Defendant's convictions; and (2) the trial judge did not impermissibly coerce the juror into reaching a unanimous verdict. View "Commonwealth v. Gibson" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree based on extreme atrocity or cruelty and the denial of Defendant's motion for a new trial, holding that there was no reversible error.Specifically, the Supreme Judicial Court held (1) there was sufficient evidence to prove extreme atrocity or cruelty; (2) the trial court did not commit prejudicial error by admitting evidence that Defendant sold marijuana as a potential motive for the crime; (3) Defendant was not entitled to a new trial based on his claims of ineffective assistance of counsel; and (4) there was no reason to grant relief under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Gonsalves" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction for simple assault and battery, holding that while Defendant's bench trial, conducted partly via Zoom, did not violate Defendant's constitutional rights, this opinion sets forth guidelines to be followed when remote bench trials are contemplated in criminal cases.Defendant's bench trial was in the midst of the COVID-19 pandemic over an Internet-based video conferencing platform. On appeal, Defendant argued that his trial violated his constitutional rights to confront the witnesses against him, to be present at trial, to have a public trial, and to have effective assistance of counsel. The Supreme Judicial Court affirmed, holding that Defendant was not prejudiced by his appearance over Zoom at his trial and did not receive ineffective assistance of counsel. Because the Court recognized that a criminal defendant's constitutional rights may be implicated when critical stages of court proceedings are conducted remotely, the Court provided guidance in this opinion to trial courts that offer defendants virtual or partly virtual bench trials during the COVID-19 pandemic. View "Commonwealth v. Curran" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions entered upon his conditional guilty plea to the charges of possession of a firearm without a license and possession of a large capacity feeding device, holding that the superior court did not err in denying Defendant's motion to suppress.On appeal, Defendant argued that the officers that stopped him after a routine traffic stop and then conducted a pat frisk did not have reasonable suspicion that he might be armed and dangerous. The Supreme Judicial Court affirmed the order denying Defendant's motion to suppress, holding that the facts, when taken together, warranted a reasonably prudent person's belief that Defendant was armed and dangerous. View "Commonwealth v. Sweeting-Bailey" on Justia Law