Justia Massachusetts Supreme Court Opinion Summaries

In the case before the Supreme Judicial Court of Massachusetts, the defendant, Sheldon Mattis, was convicted of first degree murder among other charges, and was sentenced to a mandatory term of life in prison without the possibility of parole. At the time of the murder, Mattis was eighteen years old. He appealed his sentence, arguing that it was unconstitutional as applied to him because he was an "emerging adult" (defined in this case as eighteen, nineteen, or twenty years old at the time of the crime), and should be entitled to the same protection as juvenile offenders, who receive a term of life with the possibility of parole.The court considered whether their previous ruling in Diatchenko I, which concluded that sentencing a juvenile to life without parole in any circumstance would violate the Massachusetts Declaration of Rights, should be extended to apply to emerging adults. The court reviewed scientific evidence showing that the brains of emerging adults are not fully mature and are similar to those of juveniles, and also considered the treatment of emerging adults in Massachusetts and elsewhere.The court concluded that a sentence of life without the possibility of parole for emerging adult offenders violates the Massachusetts Declaration of Rights. As a result, the court invalidated the provisions of Massachusetts law that deny the possibility of parole to emerging adults. The court remanded the matter to the lower court for resentencing consistent with the court's opinion. The court also noted that this ruling does not suggest that emerging adults receiving the benefit of resentencing should be paroled once they have served a statutorily designated portion of their sentences. Instead, the parole board should evaluate the circumstances surrounding the commission of the crime, including the age of the offender, together with all relevant information pertaining to the offender's character and actions during the intervening years since conviction. View "Commonwealth v. Mattis" on Justia Law

In the case at hand, the defendant, Joshua Hart, and his girlfriend, Brittany Smith, entered the home of an elderly couple, Thomas Harty and his wife, Joanna Fisher, intending to steal their car and money. The couple ended up fatally attacking both Harty and Fisher, and then fled the state in the victims' vehicle. Hart was convicted on two counts of first-degree murder, and he appealed on several grounds.Hart argued that his confession to law enforcement was involuntary and should have been suppressed, but the Supreme Judicial Court of Massachusetts disagreed. The court found that Hart's confession was voluntary based on the circumstances of the interrogation, his experience with the criminal justice system, and his own actions and statements during the interrogation.Hart also argued that the trial should have been moved to another venue due to pretrial publicity. The court disagreed, stating that the defendant did not provide sufficient evidence to demonstrate that the pretrial publicity caused either presumptive or actual prejudice. The court found that less than 20% of potential jurors were excused due to pretrial publicity, and the judge took extensive steps to protect Hart's right to a fair trial.Hart further contended that a statement made by the deceased victim, Fisher, to her nurse, which was relayed to the jury through the nurse's testimony, should have been excluded from evidence as it was hearsay and violated his right to confront witnesses. The court determined that Fisher's statements were non-testimonial and thus did not violate the confrontation clause. The court also found that even if Fisher's statements were admitted in error, there was no prejudice because the Commonwealth presented other compelling evidence of the facts relayed in Fisher's statements.Finally, Hart argued that his sentences of life without the possibility of parole constituted cruel or unusual punishment because he was under 25 years old at the time of the crimes. The court rejected this argument, finding no reason to extend the prohibition of life sentences without parole for juveniles to individuals under the age of 25.Accordingly, the court affirmed Hart's convictions. View "Commonwealth v. Hart" on Justia Law

In the case before the Supreme Judicial Court of Massachusetts, defendant Amadi Sosa was convicted of murder in the first degree, armed assault with the intent to rob, and unlawful possession of ammunition in connection with the shooting death of William Serrano. The defendant appealed his convictions and the denial of his motion for a new trial, alleging several errors, including that the trial judge wrongfully denied his motion for relief from a joint trial with his co-defendant, Julio Brian Leiva, and that the judge erroneously allowed the prosecutor to use an unauthenticated video recording during the trial. The court affirmed the defendant's convictions of murder in the first degree and armed assault with the intent to rob, and the denial of his motion for a new trial. However, the court vacated the defendant's conviction of unlawful possession of ammunition due to an error in the jury instructions. The court found that there was no reversible error with respect to the defendant's convictions of murder in the first degree and armed assault with the intent to rob, and declined to exercise its authority under G. L. c. 278, § 33E to grant relief or order a new trial. View "Commonwealth v. Sosa" on Justia Law

In the case of Commonwealth vs. William Omari Shakespeare, the defendant, Shakespeare, was convicted of murder in the first degree and related firearms offenses for the shooting death of Marcus Hall. Following the conviction, Shakespeare filed an appeal arguing that the evidence pointing to his guilt was insufficient and that the judge erred in not allowing the grand jury testimony of a deceased individual, Mark Edwards, who was present at the scene, to be admitted as evidence. Shakespeare also claimed that the police officer’s testimony about his observations of the video evidence was improperly admitted and that his trial counsel was ineffective.The Supreme Judicial Court of Massachusetts found that the evidence was sufficient for the conviction of murder in the first degree, however, the court concluded that it was an error to prohibit the admission of Edwards's grand jury testimony, which could have supported Shakespeare's defense that Edwards was the actual shooter. The court found that such error was not harmless beyond a reasonable doubt. Consequently, the court reversed all of Shakespeare's convictions and remanded the case for a new trial.The court also ruled that the officer's testimony about his observations of the video evidence was admissible and the trial counsel was not ineffective. View "Commonwealth v. Shakespeare" on Justia Law

The Supreme Judicial Court affirmed the judgment of a single justice of the court denying Petitioner's petition filed pursuant to Mass. Gen. Laws ch. 211, 3 seeking relief from the denial of his application for a criminal complaint, holding that Petitioner was not entitled to extraordinary relief.Petitioner filed an application seeking a criminal complaint against Respondent on three counts. The district court refused to issue the complaint, finding that no probable cause supported the first two counts. Petitioner subsequently filed this petition seeking relief from the determination that no probable cause existed to support the first count. The Supreme Judicial Court affirmed the denial of relief, holding that Petitioner was not entitled to extraordinary relief under the circumstances. View "Davis v. Noonan" on Justia Law

The Supreme Judicial Court vacated Defendant's convictions for murder in the first degree on a theory of deliberate premeditation, argued assault with intent to murder, and assault and battery by means of a dangerous weapon, holding that the trial judge prejudicially erred when it denied defense counsel's request to conduct a voir dire examination of a key witness.On appeal, Defendant argued, among other things, that the judge erred in denying his request to conduct a voir dire examination of a key prosecution witness when defense counsel received an anonymous text message suggesting that a witness had falsely identified Defendant as part of a plot to frame him. The Supreme Court vacated Defendant's convictions, holding that the judge erred in denying defense counsel's request to conduct a voir dire examination of the key identification witness, and the error was prejudicial. View "Commonwealth v. Troche" on Justia Law

The Supreme Judicial Court affirmed the judgment of the single justice denying Petitioner's petition for relief citing Mass. Gen. Laws ch. 211, 3, Mass. Gen. Laws ch, 249, 5, Mass. Gen. Laws ch. 278, 28E, 28 U.S.C. 1292(b), and Mass. R. Crim. P. 15, holding that the single justice did not err or abuse his discretion in denying relief.Petitioner, who was awaiting trial on indictments for rape, strangulation or suffocation and other offenses, filed papers seeking review of the denial of certain pretrial motions and correction of other purported errors. The single justice denied all requests for relief. The Supreme Judicial Court denied Petitioner's appeal, holding that Petitioner failed to demonstrate that review of his claims could not adequately be obtained in the trial court or on appeal from his conviction. View "Ardaneh v. Commonwealth" on Justia Law

The Supreme Judicial Court vacated a portion of its prior order remanding this case to the superior court for entry of judgments of not guilty on indictments charging unlawful possession of a firearm, unlawful possession of ammunition, and unlawful possession of a loaded firearm, holding that this Court erred.Defendant was convicted of, inter alia, firearms-related convictions. The Supreme Judicial Court vacated Defendant's convictions and ordered that the superior court judge enter judgments of not guilty on the indictments, holding that, in light of the United States Supreme Court's decision in New York Stat Rifle & Pistol Ass'n v. Bruen, 142 S. Ct. 2111, 2122 (2022), which was entered after Defendant's convictions, the trial court judge erred when he failed to instruct the jury that Defendant lacked of a firearms license. The Court then granted the Commonwealth's motion for reconsideration, vacated the relevant portion of its prior order, and remanded the case for a retrial on those indictments, holding that because the constitutional rule established in Bruen did not exist at the time Defendant was convicted, the Commonwealth should have an opportunity to retry Defendant. View "Commonwealth v. Guardado" on Justia Law

The Supreme Judicial Court affirmed the judgment of the county court denying, without a hearing, Petitioner's petition for relief under Mass. Gen. Laws ch. 211, 3, holding that Petitioner had no standing to obtain extraordinary relief in the instant matter.Petitioner filed an application in the district court for a criminal complaint charging an individual with witness intimidation and unlawful wiretapping. The application was denied due to lack of probable cause. Thereafter, Petitioner filed another application for criminal complaint in the Boston Municipal Court (BMC) charging the same individual with witness intimidation. The BMC found no probable cause and did not issue the complaint. Petitioner then brought this action, and the single justice denied relief without addressing the merits. The Supreme Judicial Court affirmed, holding that the single justice neither erred nor abused his discretion in denying relief. View "In re Two Applications for a Criminal Complaint" 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 under the statute.Petitioner was charged with one count each of assault and battery and witness intimidation. After an evaluation, a doctor recommended that Petitioner be found incompetent to stand trial and that he remain in the Tewksbury State Hospital, where he had been involuntarily committed for evaluation. Petitioner's counsel stipulated to incompetency but objected to further commitment. Petitioner was ultimately involuntarily committed for an additional thirty days. Petitioner then brought this petition asking the single justice to vacate the involuntary commitment order. The single justice denied the petition without holding a hearing. The Supreme Court affirmed, holding that Petitioner had an adequate alternative remedy. View "In re Impounded Case" on Justia Law