Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court held that Defendant did not meet the threshold under Mass. Gen. Laws ch. 278A, 3 to be entitled to a hearing on his motions for postconviction forensic testing.Defendant was convicted of premeditated murder on a theory of transferred intent based on evidence that Defendant shot at particular individuals with the intent to kill them, killing the victim. Defendant filed a motion for postconviction testing and analysis of ballistics evidence, arguing that there may have been more than one firearm present at the incident. The motion judge denied the motion without a hearing. Defendant then field a renewed motion to permit testing of ballistics evidence. The judge denied the motion. The Supreme Judicial Court affirmed, holding that Defendant did not satisfy the preliminary showing under Mass. Gen. Laws ch. 278A, 3 such that he was entitled to a hearing on his motions for postconviction forensic testing. View "Commonwealth v. Jenks" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on a theory of extreme atrocity or cruelty, holding that Defendant's allegations of error were unavailing.Specifically, the Supreme Judicial Court held (1) there was sufficient evidence to support a finding of extreme atrocity or cruelty, and therefore, the trial judge did not err in denying Defendant's motions for a required finding of not guilty; (2) there was no error in the trial judge's supplemental jury instruction; (3) the judge did not abuse her discretion in allowing the introduction of prior bad act evidence; (4) even if the prosecutor made a statement during his closing argument that crossed a line of hyperbole, there was no substantial likelihood of a miscarriage of justice; and (5) there was no error warranting relief under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. West" on Justia Law

The Supreme Judicial Court affirmed the judgment of a single justice of the court denying Petitioner's petition for relief 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 in a complaint with assault and battery on a family or household member and assault and battery on a pregnant person. Petitioner was also subject to a Mass. Gen. Laws ch. 209A order. In his Mass. Gen. Laws ch. 211, 3 petition, Petitioner challenged the lawfulness of both the criminal charges and the chapter 209A order. The single justice denied the petition without a hearing. The Supreme Judicial Court affirmed, holding that Petitioner was not entitled to review pursuant to Mass. Gen. Laws ch. 211, 3. View "Vilbon v. Commonwealth" on Justia Law

The Supreme Judicial Court affirmed the judgment of a single justice of the court denying Petitioner's petition for relief under Mass. Gen. Laws ch. 211, 3, holding that the single justice did not err or abuse his discretion in denying relief.Although Petitioner asked the court to exercise its general superintendence power pursuant to Mass. Gen. Laws ch. 211, 3, he did not identify the specific relief he was seeking. The single justice denied the petition. The Supreme Judicial Court affirmed, holding that, to the extent Petitioner sought relief from perceived injustices done or imposed on him in the trial court, his claims did not warrant extraordinary superintendence relief directly from the Supreme Judicial Court. View "Ardaneh v. Commonwealth" on Justia Law

The Supreme Judicial Court affirmed the judgment of a single justice of the court denying Petitioner's petition for relief pursuant to Mass. Gen. Laws ch. 211, 3, holding that the single justice did not err or abuse his discretion in denying relief.Petitioner's first trial ended in a mistrial. After Petitioner successfully moved to suppress a preindictment buccal swab obtained by the Commonwealth, the Commonwealth successfully moved to obtain a postindictment buccal swab from Petitioner. The superior court allowed the motion. Petitioner sought relief, and a single justice of the court denied relief, concluding that Petitioner had an adequate alternative remedy. The Supreme Judicial Court affirmed, holding that the single justice did not err or abuse his discretion in denying relief. View "Pinney v. Commonwealth" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction for murder in the first degree but remanded for resentencing in accordance with Diatchenko v. District Attorney for the Suffolk District, 466 Mass. 655 (2013), holding that because Defendant was a juvenile at the time of the offense, resentencing was required.Defendant was sixteen years old when he shot and killed a fourteen year old boy. Defendant was convicted of murder in the first degree. In accordance with Mass. Gen. Laws ch. 265, 2, as the statute stood at the time of trial, Defendant was sentenced to life in prison without the possibility of parole. The Supreme Judicial Court (1) affirmed Defendant's convictions, holding that he was not entitled to relief on any of his allegations of error; and (2) pursuant to Diatchenko, held that Defendant should be resentenced so that he will be eligible for parole on his life sentence. View "Commonwealth v. Fernandes" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions of murder in the first degree on the theory of felony-murder, unlawful possession of a firearm, and attempted armed robbery, holding that there was no error.Specifically, the Supreme Judicial Court held (1) counsel's failure to file a motion to suppress Defendant's text messages was not ineffective assistance of counsel because probable cause was established; (2) counsel was not ineffective for failing to exclude cell site location information; (3) Defendant was not was prejudiced by defense counsel's failure to object to in-court and out-of-court identifications made by an eyewitness; and (4) there was no other basis to set aside or reduce the verdict of murder in the first degree or to order a new trial under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Louis" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of felony murder but vacated Defendant's conviction of murder in the first degree and remanded the matter for entry of a verdict of guilty of murder in the second degree, holding that the conviction of murder in the first degree was invalid.Defendant was convicted of murder in the first degree on a theory of joint venture felony-murder, with aggravated kidnapping as the predicate felony. On appeal, the Commonwealth conceded that the first-degree murder conviction was invalid because, at the time of the offense, the felony of aggravated kidnapping did not exist, and therefore, Defendant could be convicted only of felony-murder in the second degree. Defendant also raised several allegations of error on appeal. The Supreme Judicial Court held (1) the interests of justice were best served by reducing the degree of guilt to murder in the second degree; and (2) Defendant was not entitled to relief on his remaining allegations of error. View "Commonwealth v. Trotto" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree, on a theory of felony order, with aggravated rape as the predicate felony, holding that there was no prejudicial error in the proceedings below.Specifically, the Supreme Judicial Court held (1) there was sufficient evidence to prove that the homicide and the aggravated rape were parts of one continuous event; (2) if there was any error in the prosecutor's closing argument, Defendant was not prejudiced by it; (3) there was no error in the judge's Tuey-Rodriguez charge to the jury; (4) the judge's response to a jury question about the permissibility of inferences from a lack of evidence did not violate Defendant's right to due process; and (5) there was no reason to reduce the verdict or to order a new trial under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Witkowski" on Justia Law

The Supreme Judicial Court affirmed the decision of the superior court allowing Defendant's motion to suppress all of the statements he made after having invoked his right to counsel, holding that the trial judge did not err in granting the motion to suppress.Defendant was arrested on charges of murder in the first degree and possession of a firearm without a license. Although Defendant first agreed to waive his Miranda rights and speak with police in an interrogation room, twenty minutes after the interview began Defendant requested to speak with an attorney. Forty-five minutes later, Defendant again waived his Miranda rights and agreed with speak with the police. Defendant was subsequently interviewed for about one hour. Thereafter, Defendant moved to suppress all of the statements he made after having invoked his right to counsel. The superior court judge allowed the motion to suppress, concluding that it had not been established beyond a reasonable doubt that Defendant reinitiated the interview and knowingly, voluntarily, and intelligently waived his right to counsel. The Supreme Judicial Court affirmed, holding that the trial judge did not err. View "Commonwealth v. Gonzalez" on Justia Law