Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court answered three reported questions regarding judicial proceedings stemming from the denial of a petition for medical parole.Plaintiffs - Raymon Harmon and Brian Racine - were prisoners who applied for release under Mass. Gen. Laws ch. 127, 119A, the medical parole statute. The Commissioner of Correction denied both petitions. Harmon sought judicial review but died while his case was pending in the superior court. Racine requested that the Commissioner reconsider her decision and died after the Commissioner denied the request. The Supreme Judicial Court held (1) a prisoner's death renders judicial proceedings stemming from the denial of a petition for medical parole moot, but a court may use its discretion to decide the case; (2) the regulations of the Department of Corrections that limit the ability of prisoners to submit subsequent petitions for medical parole after one has been denied or not acted upon are void; and (3) section 119A applies only to committed offenders serving a sentence and not to pretrial detainees. View "Harmon v. Commissioner of Correction" on Justia Law

The Supreme Judicial Court reversed Defendant's convictions of armed assault with intent to murder and related charges, holding that the trial judge erred in admitting evidence obtained from a global positioning system (GPS) device that Defendant was wearing at the time of the crime.Due to his probation on a federal drug charge, Defendant was wearing a GPS ankle monitor on the night of the shooting at issue. During trial, the court admitted data from Defendant's GPS device showing his location at the time of the shooting and that his speed matched the shooter's movements. The Supreme Judicial Court reversed Defendant's convictions, holding that because the GPS device Defendant was wearing had never been formally tested for its ability to measure speed, the trial judge abused his discretion in admitting the speed evidence. View "Commonwealth v. Davis" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on theories of both deliberate premeditation and extreme atrocity or cruelty, holding that there was no reversible error either in any issue raised by Defendant or in this Court's review under Mass. Gen. Laws ch. 33E.Specifically, the Supreme Judicial Court held (1) the trial court did not err in denying Defendant's motion to suppress handwritten note and oral statements he made to officers while he was hospitalized; (2) Defendant was not entitled to reversal of his convictions on the grounds of error in the trial judge's evidentiary rulings; (3) the trial judge did not err in denying Defendant's motion for a new trial; and (4) there was no basis for reducing Defendant's sentence on the murder conviction or ordering a new trial. View "Commonwealth v. Welch" on Justia Law

The Supreme Judicial Court affirmed the allowance of Defendant's motion for a new trial, holding that the evidence supporting the charge of armed home invasion was insufficient to allow a finding beyond a reasonable doubt on each element of the offense.Defendant was convicted of armed home invasion, armed burglary, robbery while armed and masked, and other charges. Defendant later filed a motion for a new trial on the charge of armed home invasion, arguing that there was insufficient evidence that he was armed when he entered the building. The superior court allowed the motion. The Supreme Judicial Court affirmed and vacated and set aside Defendant's conviction of armed home invasion, holding that because there was no evidence that Defendant armed himself with a weapon before he entered the building, he could not be convicted of armed home invasion. The Court remanded the matter to the superior court for reconsideration of the sentencing scheme on the remaining convictions. View "Commonwealth v. Tinsley" on Justia Law

The Supreme Court reversed the order of the superior court denying Defendant's motion for a new trial and vacated Defendant's conviction of aggravated rape, holding that Defendant was entitled to a new trial.Defendant was convicted of aggravated ripe of a child under the age of fourteen years. Defendant later filed a third motion for new trial, arguing that his defense was prejudiced by the Commonwealth's failure to disclose exculpatory evidence concerning a key witness. The Supreme Court reversed Defendant's conviction and remanded the case to the superior court for a new trial, holding (1) the undisclosed evidence was exculpatory; and (2) Defendant was prejudiced by the nondisclosure of the prosecutor's note. View "Commonwealth v. Caldwell" on Justia Law

The Supreme Judicial Court reversed the order of the trial judge denying Defendant's motion to continue his evidentiary hearing on his motion to suppress until it could be held in person, holding that the trial judge abused her discretion.Defendant, who was charged with a drug offense, filed a motion to suppress evidence and statements. After the suppression hearing was postponed for a third time because of the COVID-19 pandemic the judge ordered that the hearing take place via Zoom. Defendant filed a motion objecting to the Zoom hearing and requested that the case be continued until an in-court hearing could be held safely. The judge denied the motion. The Supreme Judicial Court reversed, holding that because Defendant waived his right to a speedy trial and there were no civilian victims or witnesses, the trial judge abused her discretion in denying Defendant's objection to conducting the evidentiary hearing on his motion to suppress via Zoom video conference. View "Diaz v. Commonwealth" 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 there was no error that would require reversal of Defendant's convictions.Defendant's first trial ended in a mistrial because the jury were unable to reach a verdict. After a retrial, Defendant was convicted of murder. On appeal, Defendant challenged the trial court's denial of his motion to suppress his cell site location information (CSLI) and any "fruits" derived from it. The Supreme Judicial Court affirmed, holding (1) law enforcement infringed upon Defendant's reasonable expectation of privacy in his CSLI without a warrant, but the error was harmless; (2) trial counsel was not ineffective for failing to instruction to certain portions of the jury instructions; and (3) Defendant was not entitled to relief on his remaining claims of error. View "Commonwealth v. Gumkowski" on Justia Law

The Supreme Judicial Court dismissed in part and affirmed in part the judgment of the single justice of the court denying Petitioners' petition filed under Mass. Gen. Laws ch. 211, 3 seeking a stay of execution of their sentences pending decisions on their motions for a new trial, holding that the single justice did not err.Joseph Pope and Floyd Hamilton (together, Petitioners) were each convicted of murder in the first degree and armed robbery. Both petitioners filed second motions for a new trial and a motion to stay execution of sentence pending decision thereon. After the superior court denied the motions Petitioners' motions to stay, Petitioners brought this Mass. Gen. Laws ch. 211, 3 petition. The single justice denied relief without a hearing. The Supreme Judicial Court held (1) Pope's appeal from the single justice's judgment was moot; and (2) the single justice did not err by denying a stay of Hamilton's sentence pending decision on his motion for a new trial. View "Pope v. Commonwealth" on Justia Law

The Supreme Judicial Court affirmed the decision of the Appeals Court affirming the denial of a single justice of the Appeals Court denying Defendant's motion to stay execution of his sentence, holding that the Appeals Court did not err in denying Defendant's motion for a stay of execution of sentence.Defendant was convicted of murder in the second degree and other offenses. Defendant later filed a motion for a new trial. The motion was denied, and Defendant's appeal was pending. Defendant also filed a motion to stay execution of sentence. A single justice denied the motion, and the court of appeals affirmed. The Supreme Judicial Court affirmed, holding that there was no error or abuse of discretion in the denial of a stay pending appeal from the denial of Defendant's motion for a new trial. View "Commonwealth v. Harris" on Justia Law

The Court of Appeals answered a question certified to it by the Federal District Court for the District of Massachusetts by holding that the thirty-day time limitation established in Mains v. Commonwealth, 433 Mass. 30 (2000), for filing a gatekeeper petition under Mass. Gen. Laws ch. 278, 33E does not apply to denials that occurred before December 13, 2000.Petitioner was convicted of murder in the first degree and armed assault with intent to murder. Petitioner later filed a federal habeas petition. Respondent filed a motion to dismiss, arguing that the petition was untimely under the deadline set forth in the Antiterrorism and Effective Death Penalty Act, 28 U.S.C. 2244(d)(1). At issue was whether the time limitation established in Mains for filing a gatekeeper petition applies to denials that occurred prior to December 13, 2000. The Court of Appeals held that pre-Mains denials continue not to be subject to any time limitation, as under pre-Mains practice. View "Mandeville v. Gaffney" on Justia Law