Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed Defendant's convictions three counts of murder in the first degree and concluded that Defendant was not entitled to relief under Mass. Gen. Laws ch. 278, 33E, holding that there was no reversible error in the proceedings below.Specifically, the Supreme Judicial Court held (1) the trial judge erred by giving a charge in accordance with Commonwealth v. Rodriguez, 364 Mass. 87 (1973), and Commonwealth v. Tuey, 8 Cush. 1, 2-3, to an individual juror after the jury had been polled, but the error was not prejudicial; (2) some the trial judge's rulings admitting prior bad acts evidence were in error, but the errors were not prejudicial; (3) the judge did not abuse his discretion in admitting coventurer statements; (4) certain remarks made by the prosecutor in opening and closing arguments were in error, but the error was not prejudicial; (5) the trial judge did not err by denying Defendant's motion to suppress; and (6) this Court declines to exercise its authority under Mass. Gen. Laws ch. 278, 33E to order a new trial or direct the entry of verdicts of a lesser degree of guilt. View "Commonwealth v. Chalue" on Justia Law

The Supreme Judicial Court affirmed the order of the superior court denying Defendant's motion for credit for time he served on a drug conviction that was vacated after the scandal at the State Laboratory Institute in Amherst at the campus of the University of Massachusetts was revealed, holding that Defendant was not entitled to mandatory credit in this case.In 2018, the Supreme Judicial Court ordered the vacated and dismissal with prejudice of thousands of drug convictions that relied on substances tested at the Amherst lab during certain periods of Sonja Farak's employment as a chemist at the lab. That same year, Defendant filed a motion for jail credit in his 2017 criminal case. The judge denied the motion, concluding that Defendant was not entitled to credit because government misconduct at a drug laboratory was not equally compelling to actual innocence. The Supreme Judicial Court affirmed, holding that, under the circumstances of this case, Defendant was not owed credit toward his conviction. View "Commonwealth v. Caliz" on Justia Law

The Supreme Judicial Court vacated Defendant's convictions of murder in the first degree and armed assault with intent to murder and affirmed Defendant's conviction of assault and battery by means of a dangerous weapon, holding that the evidence was insufficient to support the murder conviction and the assault and battery by means of a dangerous weapon convictions.At trial, the Commonwealth proceeded on a theory that Defendant had initiated a gunfight with codefendant Keith Williams and was therefore liable for harm to innocent bystanders. The Supreme Judicial Court vacated the convictions in part, holding (1) there was insufficient evidence to convict Defendant of murder in the first degree; (2) the Commonwealth failed to introduce sufficient evidence to support Defendant's conviction of assault and battery by means of a dangerous weapon; and (3) Defendant was not entitled to relief on his remaining allegations of error. View "Commonwealth v. Colas" on Justia Law

The Supreme Judicial Court vacated some of Defendant's convictions, holding that the case must be remanded for an evidentiary hearing as to Defendant's motion to suppress and a determination as to whether the first prong of the independent source exception to the exclusionary rule applied.Following two separate jury trials in the Superior Court in Norfolk County and Middlesex County Defendant was convicted of multiple offenses stemming from a burglary spree. Before trial, Defendant moved to suppress evidence seized from his residence during the execution of a search warrant, asserting that the warrant was tainted by discoveries made during an earlier unlawful entry of his residence. The motion judges agreed that the initial entry was unauthorized but that, pursuant to the independent source rule, the evidence was exempt from exclusion as "fruit of the poisonous tree." The Supreme Judicial Court vacated Defendant's Middlesex convictions with the exception of his conviction for intimidation of a witness, holding that because the matter of whether the evidence demonstrated that the detective would not have sought the warrant had the officers not made the initial illegal entry, the matter must be remanded for an evidentiary hearing. View "Commonwealth v. Pearson" on Justia Law

The Supreme Judicial Court reversed the decision of the superior court granting a new trial in this criminal case after concluding that the evidence was insufficient to support Defendant's murder conviction on a theory of joint venture felony-murder, holding that granting Defendant's motion for a new trial was error.Defendant was convicted of murder in the first degree, armed robbery, and kidnapping. The court of appeals affirmed. More than forty years later, Defendant filed a motion for a new trial on the murder indictment, arguing that the Commonwealth presented insufficient evidence for the felony-murder conviction. The superior court judge granted the motion. The Supreme Judicial Court reversed, holding (1) the motion judge had authority to consider the sufficiency of the evidence following the Supreme Judicial Court's 33E plenary review on direct appeal; but (2) Defendant was estopped from raising the claim that the evidence was insufficient for the jury to have found that Defendant was a joint venturer in the armed robbery. View "Commonwealth v. Watkins (No. 1)" 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, holding that the single justice did not err or abuse his discretion in denying relief.Petitioner was charged with solicitation to commit a crime stemming from an incident involving an informant that occurred while Petitioner was incarcerated. During the trial court proceedings, Petitioner filed two motions seeking discovery related to the informant and an evidentiary hearing to determine whether the Department of Correction was a third party. The trial court judge denied both motions. Petitioner then filed his Mass. Gen. Laws ch. 211, 3 petition asking the single justice to vacate the trial court's orders denying his discovery-related motions. The single justice denied the petition. The Supreme Judicial Court affirmed, holding that because Petitioner could seek review of any error in the normal appellate process the single justice properly denied relief. View "Quinones v. Commonwealth" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction for murder in the first degree with deliberate premeditation, holding that there was no reversible error in the proceedings below and no reason for this Court to exercise its authority under Mass. Gen. Laws ch. 278, 33E to reduce or set aside the verdict.Specifically, the Supreme Judicial Court held that the trial judge did not commit prejudicial error in (1) allowing the Commonwealth's peremptory challenges of two prospective jurors over Defendant's objections pursuant to Batson v. Kentucky, 476 U.S. 79 (1986), and Commonwealth v. Soares, 377 Mass. 461 (1979); (2) admitting a graphic autopsy photograph; and (3) allowing rebuttal testimony about overheard telephone statements of a Commonwealth witness imparting that she altered her testimony upon receipt of death threats and denying Defendant's request to conduct consequent voir dire of that witness. View "Commonwealth v. Jackson" on Justia Law

The Supreme Judicial Court affirmed the decision of the Sex Offender Registry Board ordering John Doe to register as a level three offender, holding that the Board's decision was not arbitrary or capricious and was supported by substantial evidence.On appeal, Doe argued that the Board should be required to prove new sex offenses by clear and convincing evidence and that the Board's decision was improper because it was not based on new information and the hearing was not held within a reasonable time. The Supreme Judicial Court disagreed, holding (1) subsidiary facts, including new sex offenses, need be proved by a preponderance of the evidence, and regardless, there was clear and convincing evidence supporting the level three upward reclassification; and (2) because the Board initiated the reclassification process shortly after receiving information of the new sex offense charges, and because the delays in reaching a final decision were not unreasonable, the Board's decision was proper. View "Doe v. Sex Offender Registry Board" on Justia Law

The Supreme Judicial Court held that "a first offense of a [minor] misdemeanor" in Mass. Gen. Laws ch. 119, 52 refers to a first episode of minor misdemeanor level misconduct.Four juveniles with no prior offenses were charged with several offenses, including several minor misdemeanors and a felony charge of inciting a riot, all arising from the same episode. A juvenile court judge dismissed the charges of inciting a riot against all three juveniles and decided not to immediately arraign on the minor misdemeanor charges. At issue was which of the charges constitutes a first offense of a minor misdemeanor pursuant to Mass. Gen. Laws ch. 119, 52. The Supreme Judicial Court held (1) all of the minor misdemeanors arising out of the single episode for each juvenile constituted a first offense for which the legislature intended a second change and must be dismissed, but the Commonwealth may proceed directly to arraignment on the greater offenses; (2) there was no probable cause to support the charge of inciting a riot; and (3) Mass. Gen. Laws ch. 264, 11 must be read consistently with the limitations in Brandenburg v. Ohio, 395 U.S. 444 (1969). View "Commonwealth v. Manolo M." 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 a superior court judge's order denying his motion to continue the third day of an evidentiary suppression hearing, holding that the single justice did not err or abuse his discretion.At issue before the single justice was whether the trial judge's directive to Petitioner to make a choice whether to appear for an evidentiary hearing in person or via video conference was sufficiently important and extraordinary as to warrant the exercise of the Supreme Judicial Court's extraordinary power pursuant to Mass. Gen. Laws ch. 211, 3. The Supreme Judicial Court held that the single justice did not err or abuse his discretion in denying Petitioner's petition. View "Malary v. Commonwealth" on Justia Law