Justia Massachusetts Supreme Court Opinion Summaries

In these two cases in which Defendants sought stays of execution of their sentences pending appeal, the Supreme Judicial Court provided additional guidance as to how judges who are faced with requests for stays should take into account the COVID-19 pandemic as a factor in determining whether a stay is appropriate in any given case.In Daniel Nash's case, the trial judge granted a stay, which a single justice of the Appeals Court vacated. In Joseph Elibert's case, the trial court granted a stay but later revoked it, and a single justice of the Appeals Court affirmed. The Supreme Judicial Court reversed the judgments of the Appeals Court single justice in each case after addressing the procedural issues concerning these cases, holding that both defendants were entitled to a stay. View "Commonwealth v. Nash" on Justia Law

The Supreme Judicial Court held that the Civil Defense Act (CDA), Mass. Gen. Laws ch. 17, 2A, provided the Governor with the authority for his March 10, 2020 declaration of a state of emergency in response to the COVID-19 pandemic and for his issuance of the emergency orders and that the emergency orders did not violate article 30 of the Massachusetts Declaration of Rights or Plaintiffs' federal or state constitutional rights to procedural and substantive due process or free assembly.Plaintiffs brought this complaint seeking declaratory judgment and injunctive relief, challenging the Governor's declaration of a state of emergency and the emergency orders placing restrictions on daily activities as unauthorized and unconstitutional. The Supreme Judicial Court denied relief, holding that Plaintiffs' claims were unavailing and that the emergency orders were authorized and constitutional. View "Desrosiers v. The Governor" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions of distribution of a class A controlled substance and committing the crime within one hundred feet of a public park, holding that Defendant's arguments on appeal were unavailing.Defendant appealed from the denial of his motion for a required finding of not guilty, claiming, among other things, that there was insufficient evidence proving that the area was a public park within the meaning of Mass. Gen. Laws ch. 94C, 32J. The Supreme Judicial Court affirmed, holding (1) the evidence presented was sufficient for the jury to find that the park at issue was a park within the meaning of section 32J; and (2) although the judge's instructions did not include a definition of a "public park," the instructions did not result in a substantial risk of a miscarriage of justice. View "Commonwealth v. Ramos-Cabrera" on Justia Law

The Supreme Judicial Court vacated Defendant's conviction for committing the crime of distribution of cocaine within one hundred feet of a public park in connection with a sale of the controlled substance to an undercover officer, holding that the Commonwealth failed to prove that the area in question was a "public park" for purposes of Mass. Gen. Laws ch. 94C, 32J.On appeal, Defendant argued that the Commonwealth provided insufficient evidence that the park at issue was public within the meaning of the statute. The Supreme Judicial Court agreed, holding that the section 32J conviction could not stand because there was no evidence that Defendant was within one hundred feet of an area owned or maintained by a governmental entity. View "Commonwealth v. Boger" on Justia Law

The Supreme Court affirmed the judgment of the single justice denying Defendant's petition filed pursuant to Mass. Gen. Laws ch. 211, 3 seeking to remove the conditions of GPS monitoring and home confinement on Defendant's release, holding that the conditions were constitutional.Defendant was convicted of trafficking narcotics. Defendant filed a motion for a new trial and sought to stay the execution of her sentence while her motion was pending. The trial judge granted the stay and imposed the conditions of release at issue. Defendant then filed a petition in the county court seeking relief from the conditions. The single justice denied relief. The Supreme Judicial Court affirmed, holding (1) the condition of home confinement was not a seizure because it was imposed pursuant to a valid conviction and lawful sentence; and (2) the imposition of GPS monitoring was a search, but it was reasonable under the circumstances. View "Garcia v. Commonwealth" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree, assault and battery by means of a dangerous weapon, and improper disposition of a human body, holding that there was no prejudicial error in the proceedings below.On appeal, Defendant argued that the trial court erred in denying his motion to suppress his cell site information (CSLI) because it was obtained by police without a warrant and that a subsequent search pursuant to a warrant for the same information was tainted by the initial warrantless search. The Supreme Judicial Court disagreed, holding (1) the trial judge did not err in failing to suppress Defendant's CSLI, and the motion judge did not err in denying Defendant's motion for a new trial and for an evidentiary hearing on this same basis; (2) trial counsel's failure to move to suppress the fruits of the initial illegal search did not result in a substantial likelihood of a miscarriage of justice; and (3) there was no reason to grant a new trial or set aside the jury's verdict under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Wilson" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on the theory of felony murder, with armed robbery as the predicate felony, holding that there was no prejudicial error in the proceedings below.Specifically, the Supreme Judicial Court held (1) the trial judge did not err by not providing, sua sponte, an instruction on felony murder in the second degree; (2) the admission of Defendant's cell site location information did not result in a substantial likelihood of a miscarriage of justice; (3) the trial judge did not err in denying Defendant's motion to admit privileged psychiatric records; (4) there was no prejudicial error in the judge's decision prohibiting Defendant from eliciting certain testimony as hearsay on cross-examination; (5) the judge did not err in instructing the jury on inferences; (6) trial counsel provided effective assistance; and (7) there was no reason for the Court to exercise its authority under Mass. Gen. Laws ch. 278, 33E to reduce Defendant's verdict or order a new trial. View "Commonwealth v. Chesko" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions for murder in the first degree on a theory of deliberate premeditation and unlawful possession of a firearm, holding that there was no prejudicial error in the proceedings below.On appeal, Defendant argued that his trial counsel provided ineffective assistance, that the judge erred in allowing the introduction of certain evidence, and that the judge abused his discretion in allowing the prosecutor to exercise a peremptory challenge. The Supreme Judicial Court affirmed, holding (1) Defendant did not receive ineffective assistance of counsel; (2) there was no reversible error from the admission of the challenged evidence; (3) there was no abuse of discretion in the judge's finding that Defendant did not establish a prima facie case of excluding black jurors; and (4) there was no basis for the Court to exercise its authority under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Henderson" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree, holding that Defendant failed to demonstrate that his trial counsel was ineffective and that the trial court did not err in denying Defendant's motion for a new trial.In this appeal, which the Supreme Court consolidated with the denial of Defendant's motion for a new trial, Defendant argued that his trial counsel was ineffective for not moving to suppress his optical records and his cell site location information. The Supreme Court affirmed, holding (1) Defendant's trial counsel provided effective assistance; (2) the trial court did not err in denying Defendant's motion for a new trial; and (3) there was no reason to vacate Defendant's conviction or to order a new trial pursuant to Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Gosselin" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions of two counts of murder and other crimes, holding that any error committed during the proceedings below was not prejudicial.Specifically, the Supreme Judicial Court held (1) the trial judge's admission of a DNA expert's testimony regarding a "nonexclusion" result; (2) the trial judge did not err in admitting into evidence charts depicting DNA test results; (3) the prosecutor erred in misstating certain evidence, but the error was not prejudicial; (4) the judge's jury instruction that prior inconsistent statements may not be considered substantively was erroneous, but the error did not prejudice Defendant as to require a new trial; (5) the trial judge did not err in denying Defendant's motion for a new trial on the grounds that a purported courtroom closure during voir dire was unconstitutional; and (6) following plenary review of the record pursuant to Mass. Gen. Laws ch. 278, § 33E, there was no basis for reducing Defendant's sentence on the murder conviction or ordering a new trial. View "Commonwealth v. Lester" on Justia Law