Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court declared that periods of delay resulting from trial continuances pursuant to the Court's emergency orders should be excluded from the computation of time limits on pretrial detention under Mass. Gen. Laws ch. 276, 58A and 58B.In response to the COVID-19 pandemic, the Supreme Judicial Court issued a series of emergency orders designated to protect the public health by minimizing the need for in-person proceedings at court houses. In the orders, the Court continued all criminal jury trials to a date no earlier than September 8, 2020 and declared that the time periods of the trial continuances shall be excluded from speedy trial computations. At issue in these three cases was whether the periods of delay resulting from continuances pursuant to the Court's emergency orders should be excluded from the computation of statutory time limits on pretrial detention under Mass. Gen. Laws ch. 276, 58A or 58B. The Supreme Judicial Court remanded the cases to the single justice for entry of orders directing the lower courts to reconsider their prior orders releasing Defendants from detention under chapter 276, sections 58A and 58B, holding that the time periods of these continuances must be excluded in computing the time limits on pretrial detention. View "Commonwealth v. Lougee" on Justia Law

The Supreme Judicial Court affirmed the judgment of the single justice denying, without a hearing, Defendant's petition for relief under Mass. Gen. Laws ch. 211, 3, holding that the single justice neither erred nor abused his discretion by denying relief.After Defendant's motion to suppress was allowed, the Commonwealth applied for leave to prosecute an interlocutory appeal. A single justice allowed the application and directed the appeal to the Appeals Court. An interlocutory appeal was entered more than a year after the single justice granted the Commonwealth leave to appeal. Defendant filed a motion to dismiss the underlying charges, arguing that his speedy trial and due process rights had been violated. The motion was denied. Defendant then filed his Mass. Gen. Laws ch. 211, 3 petition seeking leave to cross-appeal from the denial of his motion to dismiss. The single justice denied relief. The Supreme Court affirmed, holding that Defendant did not show that the ordinary process of trial and appeal was inadequate for him to obtain review of his speedy trial and due process claims. View "Ramos v. Commonwealth" on Justia Law

The Supreme Court affirmed the judgment of a single justice denying the Commonwealth's petition, filed pursuant to Mass. Gen. Laws ch. 211, 3, for relief from an interlocutory order the superior court in an underlying criminal case without deciding the merits, holding that the single justice did not abuse her discretion in denying the petition.Defendant was indicted on numerous firearm and ammunition charges. Defendant filed in the trial court a motion for discovery pursuant to Mass. R. Crim. P. 17(a)(2) seeking Boston police department records concerning social media surveillance on Snapchat. In his motion, Defendant asserted that the Boston police department was using Snapchat as an investigatory tool almost exclusively against black males and sought discovery he claimed would support a claim of racial discrimination. The superior court judge allowed the motion. The Commonwealth filed its Mass. Gen. Laws ch. 211, 3 petition, arguing that the judge erred in concluding that Defendant had met his burden in asserting selective prosecution that would warrant the requested discovery. The single justice denied the petition. The Supreme Judicial Court affirmed, holding that the matter did not warrant the exercise of the Court's extraordinary general superintendence power. View "Commonwealth v. Dilworth" on Justia Law

The Supreme Judicial Court held that the sentencing judge imposed illegal sentences by entering continuances without a finding and immediately dismissing criminal charges without imposing any terms and conditions or probation, but the Court declined to remand the case for resentencing as to the legal sentences because ordering Defendant to be resentenced would not be just.Defendant was charged with several offenses in connection with three separate instances. The judge sentenced Defendant to thirty days in a house of correction for the charge of assault and battery and entered continuances without a finding and dismissed all remaining charges. The Commonwealth appealed, arguing that the continuances without a finding, which were immediately dismissed without any terms and conditions, constituted illegal sentences under Mass. Gen. Laws ch. 278, 18. The Supreme Judicial Court held (1) the continuances without a finding constituted illegal sentences because they contained no terms and conditions; but (2) it would be unfair to Defendant to vacate a disposition reflecting what appeared to be a common practice, and so this ruling applies prospectively from the date of this decision. View "Commonwealth v. Ellsworth" on Justia Law

The Supreme Judicial Court declined to remand this case for resentencing, holding that the sentencing judge imposed an illegal sentence by entering a continuance without a finding and immediately dismissing a charge absent any terms and conditions or probation but that this holding shall apply prospectively from the date of this decision.Defendant was charged with five counts, including breaking and entering, and admitted to sufficient facts as to all five counts. The sentencing facts found facts sufficient for a guilty plea and entered a continuance without a finding as to the breaking and entering charge. The judge ordered the dismissal of the charge for 4 p.m. that day and did not set any conditions or terms on the dismissal. The Supreme Judicial Court held (1) the continuance without a finding amounted to an illegal sentence; but (2) this holding applies prospectively from the date of this decision. View "Commonwealth v. Rossetti" on Justia Law

The Supreme Judicial Court affirmed the entry of continuance without a finding and immediate dismissal of the criminal case but held that the disposition cannot be imposed in any such future case because, without the imposition of terms and conditions or probation, the continuance without a finding constituted an illegal sentence and that this disposition shall apply prospectively from the date of this decision.Defendant was charged with counterfeit drug possession with intent to distribute and other crimes. Defendant admitted to sufficient facts as to the crime. As to the counterfeit drug charge, the sentencing judge found sufficient facts and entered a continuance without a finding. The Commonwealth filed a motion requesting that the sentencing judge revise or revoke the entry of the continuance without a finding because the order was an "illegal disposition" contrary to Mass. Gen. Laws ch. 278, 18. The judge denied the motion without a hearing. The Supreme Judicial court affirmed, holding (1) because the sentencing judge did not impose any terms or conditions on the record, the continuance without a finding was an illegal disposition; and (2) this holding shall apply prospectively from the date of this decision. View "Commonwealth v. Beverly" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions for murder in the first degree and other crimes, affirmed orders denying Defendant's pretrial and postconviction motions, and declined to grant extraordinary relief pursuant to Mass. Gen. Laws ch. 278, 33E, holding that no reversible error occurred in the proceedings below.Specifically, the Supreme Judicial Court held (1) the trial judge did not err in deciding not to instruct the jury on self defense; (2) although it was error to require that Defendant's testimony take narrative form without his attorney's express prior invocation of Mass. R. Prof. C. 3.3(e), there was no substantial likelihood of a miscarriage of justice arising out of this error; (3) the trial judge did not err in denying Defendant's pretrial motion to dismiss the indictments; and (4) the trial judge properly denied Defendant's pretrial motion to suppress certain statements he made to officers at the police station without the benefit of prior Miranda warnings. View "Commonwealth v. Miranda" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions for murder in the first degree and felony murder and declined to exercise its authority to reduce or set aside the murder verdict, holding that the record revealed no basis to support relief under Mass. Gen. Laws ch. 278, 33E.Specifically, the Supreme Judicial Court held (1) there was no error, constitutional or otherwise, regarding the manner in which defense counsel and the trial judge invoked Mass. R. Prof. C. 3.3 (e), as appearing in 471 Mass. 1416 (2015), and related procedures approved in Commonwealth v. Mitchell, 438 Mass. 535 (2003); (2) the trial court did not err by allowing the testimony of a substitute medical examiner; (3) the trial judge's failure to sever Defendant's trial from that of his codefendant did not result in prejudicial error; and (4) Defendant's conviction of and sentencing for both felony-murder, with attempted armed robbery as the predicate felony, and armed assault with the intent to rob did not violate the double jeopardy clause of the Fifth Amendment. View "Commonwealth v. Leiva" on Justia Law

The Supreme Judicial Court affirmed Defendants' convictions and the orders denying their motions for a new trial and for postconviction relief but remanded the matter of Sheldon Mattis's sentence for an evidentiary hearing, holding that the record was insufficient to address the issue of whether a term of life without the possibility of parole for an individual between the age of eighteen and twenty-two years old violates the prohibition against cruel or unusual punishment.Defendants, Nyasani Watt and Sheldon Mattis, were convicted of murder in the first degree and related crimes. In addition to other claims, Mattis appealed from his mandatory sentence of life without the possibility of parole, arguing that, due to his age of eighteen, the sentence was unconstitutional. The Supreme Judicial Court held (1) there was no prejudicial error in the trial judge's challenged evidentiary rulings; (2) the judge did not err in failing to provide an involuntary manslaughter instruction; (3) remand was required for development of the record with regard to research on brain development after the age of seventeen; (4) the trial court did not err in denying Defendants' motions for a new trial; and (5) there was no reason to grant either defendant extraordinary relief pursuant to Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Watt" on Justia Law

In this case brought by incarcerated individuals challenging the conditions of confinement during the COVID-19 pandemic the Supreme Judicial Court allowed the parole board's motion to dismiss only with respect to the claims of the individuals civilly committed and allowed the Governor's motion to dismiss, holding that the Governor was not liable under the facts alleged.The complaint alleged that by confining Plaintiffs under conditions that put them in grave and imminent danger of contracting the COVID-19 virus and by failing to reduce the incarcerated population, Defendants were violating Plaintiffs' right to be free from cruel and unusual punishment and their right to substantive due process. Further, Plaintiffs alleged that confining persons who have been civilly committed under Mass. Gen. Laws ch. 123, 35 in correction facilities violates the individuals' rights to substantive due process. The Supreme Judicial Court (1) granted the Governor's motion to dismiss, holding that the Governor's presence was not necessary to provide any relief that a court may order in this case; and (2) allowed the parole board's motion to dismiss only with respect to the claims of individuals civilly committed, holding that if Plaintiffs' constitutional claims were to prevail, the parole board would be a logical and necessary party to accomplish a reasonable remedial process. View "Foster v. Commissioner of Correction (No. 2)" on Justia Law