Justia Massachusetts Supreme Court Opinion Summaries
Articles Posted in Criminal Law
Commonwealth v. Paige
The Supreme Judicial Court affirmed Defendant's conviction of felony-murder in the first degree with aggravated rape as the predicate offense, holding that there was no prejudicial error in the proceedings below and that the trial court did not err in denying Defendant's motion for a new trial.Specifically, the Supreme Judicial Court held (1) there was sufficient evidence to support the conviction; (2) the trial judge did not err in not giving a consciousness of guilt instruction; (3) the prosecutor did not argue facts not in evidence
during closing argument; (4) the trial judge properly denied Defendant's motion for a mistrial after the jurors inadvertently were exposed to inadmissible evidence; and (5) there was no reason to reduce the verdict pursuant to G. L. c. 278, § 33E. View "Commonwealth v. Paige" on Justia Law
Posted in:
Criminal Law
Commonwealth v. Lessieur
The Supreme Judicial Court affirmed the order of the superior court judge denying Defendant's motion for a new trial, holding that the judge did not err because the motion did not raise any error that suggested a miscarriage of justice at the original trial or that otherwise indicated a need for a new trial.Defendant was convicted of murder in the first degree. The convictions were affirmed on direct appeal. Defendant later filed a motion for postconviction testing of blood found in the snow under the victim's head, and the results of DNA testing showed the presence of DNA that was neither the victim's nor Defendant's. Defendant then filed a second motion for a new trial stemming from the new DNA results, as well as a new affidavit from a potential witness. The superior court judge denied the motion without a hearing. The Supreme Judicial Court affirmed, holding that the motion judge did not err in denying Defendant's motion for a new trial. View "Commonwealth v. Lessieur" on Justia Law
Posted in:
Criminal Law
Commonwealth v. Jacobs
The Supreme Judicial Court affirmed Defendant's convictions for murder in the first degree and unlawful possession of a firearm and the order denying his motion for a new trial, holding that there was no error.After the trial court denied Defendant's motion to reduce the verdict of murder in the first degree Defendant's motion for a stay of appeal was allowed so that he could pursue a motion for a new trial. A superior court judge denied the motion. The Supreme Judicial Court affirmed, holding (1) the trial judge did not err in denying Defendant's motion for a mistrial on the grounds of juror misconduct; and (2) there was no reason to grant relief under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Jacobs" on Justia Law
Posted in:
Criminal Law
Commonwealth v. Kozubal
The Supreme Judicial Court affirmed Defendant's convictions with the exception of two counts, which the Court vacated under Mass. Gen. Laws ch. 265, 13B 1/2, holding that Defendant's convictions stemming from incidents that occurred where the jury found Defendant was not acting in his official capacity as a mandated reporter must be set aside.Defendant was convicted of various charges of indecent assault and battery on a person under the age of fourteen by a mandated reporter, Mass. Gen. Laws ch. 265, 13B 1/2, and indecent assault and battery on a person under the age of fourteen, Mass. Gen. Laws ch. 265, 13B, holding (1) the trial judge did not err in denying Defendant's peremptory challenge of a racial minority juror; (2) even if the admission of text messages between Defendant and the victim was erroneous, there was no prejudice; (3) there was no error in the prosecutor's closing argument; (4) the jury instruction on the definition of mandated reporter was not erroneous; and (5) pursuant to this Court's ruling in Commonwealth v. Gomes, 483 Mass. 123 (2019), two of Defendant's convictions under section 13B 1/2 must be set aside and the case remanded for entry of a judgment of guilty of the lesser included offense of indecent assault and battery on a person under the age of fourteen. View "Commonwealth v. Kozubal" on Justia Law
Posted in:
Criminal Law
Torres v. Commonwealth
The Supreme Judicial Court affirmed the judgment of the superior court denying Petitioner's petition for relief pursuant to Mass. Gen. Laws ch. 211, 3, holding that the single justice did not err in denying relief.Petitioner, who was awaiting trial on two counts of murder in the first degree and related firearm offenses, brought this action challenging the trial court's grant of the Commonwealth's motion for a protective order prohibiting defense counsel from providing Petitioner with copies of certain discovery materials. In his petition, Petitioner argued that the order would violate his constitutional right to prepare his defense. The single justice denied the petition without holding a hearing. The Supreme Judicial Court affirmed, holding that Petitioner failed to establish that the remedy of direct appeal would be inadequate in his case. View "Torres v. Commonwealth" on Justia Law
Posted in:
Constitutional Law, Criminal Law
Commonwealth v. Andrade
The Supreme Judicial Court affirmed Defendant's convictions of murder in the first degree, assault and battery by means of a dangerous weapon, and other offenses, holding that Defendant was not entitled to reversal of his convictions.After he entered his appeal, Defendant filed a motion for a new trial. The superior court declined to act on the motion, as the Supreme Court would be reviewing the record. In his trial appeal, Defendant raised thirteen claims of error, and in his motion for a new trial, Defendant raised a number of claims that were also made virtually identically in his direct appeal. The Supreme Judicial Court affirmed, holding that Defendant was not entitled to relief as to either either his allegations of error on appeal or his motion for a new trial. View "Commonwealth v. Andrade" on Justia Law
Commonwealth v. Alemany
The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on theories of deliberate premeditation, extreme atrocity or cruelty, felony-murder, and other offenses, holding that there was no prejudicial error in the proceedings below.Specifically, the Supreme Judicial Court held (1) the judge's instructions on criminal responsibility contained an error of law, but the error did not rise to the level of a substantial likelihood of miscarriage of justice; (2) the prosecutor's remarks during opening statement and closing argument did not create a substantial likelihood of a miscarriage of justice; (3) the motion judge did not err in denying Defendant's request for a hearing and his motion for a new trial; and (4) no relief was warranted under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Alemany" on Justia Law
Posted in:
Criminal Law
Commonwealth v. Henry
The Supreme Judicial Court affirmed the judgment of the superior court denying Defendant's motion to withdraw his guilty pleas to indictments charging robbery, assault and battery by means of a dangerous weapon, unlawful possession of a firearm, and possession with intent to distribute a controlled substance, holding that Defendant was not entitled to relief.After learning of Annie Dookhan's misconduct in falsifying drug test results at the William A. Hinton State Laboratory Institute, Defendant filed a motion to withdraw his guilty pleas. Defendant's drug conviction was subsequently vacated. The superior court then denied Defendant's motion to withdraw his guilty pleas with respect to the non-drug-related charges. The superior court judge denied the motion, and the appeals court affirmed. The Supreme Judicial Court affirmed, holding that where a plea agreement involved multiple charges, some drug-related and others not, the presumption of governmental misconduct applies only to the tainted drug convictions. View "Commonwealth v. Henry" on Justia Law
Committee for Public Counsel Services v. Barnstable County Sheriff’s Office
The Supreme Judicial Court held that the responses of the named sheriff's offices in this complaint and their respective houses of correction to the COVID-19 pandemic did not violate Federal and State constitutional minimum requirements.At issue in this case was whether three alleged failures by certain of the Commonwealth's county sheriffs in their responses to the COVID-19 pandemic, including a failure to implement adequate COVID-19 testing strategies by the thirteen named defendants, violated Federal and State constitutional requirements. The Supreme Judicial Court denied relief, holding that there was no Federal or State constitutional violation as a result of Defendants' failure to implement comprehensive routine screening testing for COVID-19, to reduce population levels in the houses of correction, or to make more available three-way video conferencing for the purpose of attorney-client communication. View "Committee for Public Counsel Services v. Barnstable County Sheriff's Office" on Justia Law
Emma v. Massachusetts Parole Board
The Supreme Judicial Court held that the medical parole scheme set forth in the Medical Parole Act, Mass. Gen. Laws ch. 127, 119A, authorizing the Commissioner of Correction to grant medical parole to terminally ill or permanently incapacitated prisoners, while delegating to the parole board oversight of a medical parolee's compliance with the conditions of parole imposed, does not offend due process.Plaintiff, an inmate, filed a petition for medical parole after being diagnosed with terminal cancer. Plaintiff was subsequently released on medical parole but later arrested for violating the terms of his release. Plaintiff's parole was later revoked, and the Commissioner denied Plaintiff's second petition for medical parole. Plaintiff then sought release from custody, and a single justice denied the request. The Supreme Judicial Court answered reported questions regarding the Medical Parole Act by holding that the statutory and regulatory scheme concerning the revocation of medical parole does not violate a parolee's right to due process. View "Emma v. Massachusetts Parole Board" on Justia Law