Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed Defendant's conviction of two counts of possession of child pornography, in violation of Mass. Gen. Laws ch. 272, 29C, holding that the information in the search warrant was sufficient for a magistrate to have found probable cause.Seven months after Defendant's alleged illegal activity, a police trooper obtained a warrant authorizing a search of all computer systems and digital storage devices located within Defendant's residence for evidence of child pornography. During the execution of a search warrant Defendant's laptop computer and flash drive were seized. On appeal from his conviction, Defendant argued that the passage of seven months between the alleged upload of child pornography and the application for a search warrant rendered the warrant stale so that it lacked probable cause. The Supreme Judicial Court affirmed, holding that the motion judge did not err in finding that the information in the warrant affidavit was not stale when the warrant was filed. View "Commonwealth v. Guastucci" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions of carrying a firearm without a license and of possessing a loaded firearm, holding that no prejudicial error occurred in the proceedings below.Specifically, the Supreme Judicial Court held (1) the motion judge did to err in denying Defendant's motion to suppress the firearm; (2) there was sufficient evidence to support the conviction of possession of a loaded firearm; (3) the trial court's failure to instruct the jury that Defendant had to know that the firearm was loaded did not create a substantial risk of a miscarriage of justice; and (4) there was no error in the prosecutor's closing arguments. View "Commonwealth v. Silvelo" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree and the denial of his motion for a new trial and declined to exercise its authority under Mass. Gen. Laws ch. 278, 33E to reduce the verdict or order a new trial, holding that none of the errors during trial created a substantial likelihood of a miscarriage of justice.A jury found Defendant guilty of murder in the first degree on the theories of deliberate premeditation and extreme atrocity or cruelty. The Supreme Judicial Court affirmed, holding (1) trial counsel erred by failing to engage a medical expert to opine on the voluntariness of Defendant's statements after surgery and on whether his waiver of Miranda rights was knowing and voluntary, but the error did not create a substantial likelihood of a miscarriage of justice; (2) trial counsel was not ineffective for conceding certain points during closing argument; and (3) the trial judge erred in instructing the jury as to some issues, but the error did not create a substantial likelihood of a miscarriage of prejudice. View "Commonwealth v. Richards" on Justia Law

The Supreme Judicial Court vacated Defendant's conviction of murder in the first degree on the theory of extreme atrocity or cruelty, holding that there was a substantial likelihood of a miscarriage of justice arising from the application of the model jury instructions regarding criminal responsibility to the particular facts of this case.On issue at trial was whether the Commonwealth had proved beyond a reasonable doubt that Defendant was criminally responsible for the killing of a patient at the psychiatric ward of the University of Massachusetts Memorial Medical Center, where Defendant was also a patient. The Supreme Judicial Court vacated the convictions, holding that, in view of the substantial evidence that Defendant had a mental disease or defect and that he lacked substantial capacity at the time of the killing, there was a substantial likelihood of a miscarriage of justice arising from the risk of the jury's having misunderstood the model jury instructions. The Court also provisionally revised its model jury instructions regarding criminal responsibility to address what it concluded as a problematic risk of confusion. View "Commonwealth v. Dunphe" on Justia Law

The Supreme Judicial Court vacated the verdict of murder in the first degree and the sentence imposed in this case and remanded the matter to the superior court with directions to enter a verdict of guilty of murder in the second degree and to sentence Defendant accordingly, holding that a verdict of murder in the second degree was the most just verdict in this case.After a jury trial, Defendant was convicted of murder in the first degree on the theory of extreme atrocity or cruelty and sentenced to life without the possibility of parole. The Supreme Judicial Court vacated the conviction, holding (1) this Court's jury instructions regarding all of the extreme atrocity or cruelty factors set forth in Commonwealth v. Cunneen, 389 Mass. 216, 227 (1983) prospectively to more closely comport with the meaning given to the term "extreme atrocity or cruelty" are hereby revised and included in this opinion; and (2) based on the evidence of extreme atrocity or cruelty in this case, this Court exercises its authority under Mass. Gen. Laws ch. 278, 33E to reduce the degree of guilt to murder in the second degree, which, in light of the facts of this case, is a verdict more consonant with justice. View "Commonwealth v. Castillo" on Justia Law

The Supreme Judicial Court reversed the judgment of the district court finding that Defendant violated a special condition of probation and vacating the findings that Defendant violated his conditions of probation, holding that Defendant's actions were not prohibited by his probation condition.A district court judge found that Defendant, a self-employed home improvement contractor, violated a special condition of probation because he did not report as a work address on a sex offender registration form the home in Lynn where he was doing repair work. The judge also found that Defendant violated the special condition of probation that he not "work...with children" because there was an infant in the home where he worked. The Supreme Judicial Court reversed, holding (1) Defendant's "work address" was his home address for sex offender registration purposes; and (2) Defendant did not "work with children" in replacing a gutter or restoring exterior woodwork. View "Commonwealth v. Harding" on Justia Law

The Supreme Judicial Court held that due process does not permit a juvenile court judge to conduct a transfer hearing pursuant to Mass. Gen. Laws ch. 119, 72A where the defendant, now an adult, is incompetent to stand trial for a crime allegedly committed as a juvenile.Defendant was arraigned in the juvenile court on charges of indecent assault and battery on a child under fourteen and indecent assault and battery on a mentally disabled person. Defendant was a twenty-year-old adult when the delinquency complaint was brought. The juvenile court declared Defendant legally incompetent to stand trial. Thereafter, the Commonwealth requested a section 72A transfer hearing. Defendant moved to stay the hearing, which the juvenile court denied. Defendant petitioned for extraordinary relief pursuant to Mass. Gen. Laws ch. 211, 3. The Supreme Judicial Court reversed the juvenile court's order denying Defendant's motion to stay the section 72A hearing until Defendant is competent to stand trial, holding that due process does not permit a section 72A transfer hearing to proceed while the defendant is incompetent to stand trial. View "In re Juvenile" on Justia Law

The Supreme Judicial Court vacated Defendant's guilty plea to a sentencing enhancement and his conviction of unlawful possession of a loaded firearm, holding that where a defendant makes a good faith claim that a deliberating juror reported that racial bias infected the jury's deliberations, a judge may not condition acceptance of a guilty plea to a sentencing enhancement upon a waiver of that claim.Immediately after entry of the guilty verdict in this case, a deliberating juror reported that racial bias influenced the jury's deliberations. Defendant filed a motion to investigate the juror's claims prior to the jury-waived trial on two sentencing enhancements. The prosecutor agreed to nol pros one sentencing enhancement in return for Defendant's guilty plea to the other sentencing enhancement if Defendant withdrew the motion. Defendant withdrew the motion and pleaded guilty to one of the sentencing enhancements. Defendant later moved, unsuccessfully, for a new trial, seeking to vacate his guilty plea to the sentencing enhancement. The Supreme Court ordered a new trial as to the sentencing enhancements, holding that once a defendant's right to a jury trial is invoked a defendant may not waive his right to a verdict that is untainted by racial or ethnic bias. View "Commonwealth v. McCalop" on Justia Law

The Supreme Judicial Court vacated the judgment of the trial court granting summary judgment on several claims against police officers personally, holding that there was a genuine issue of material fact whether the police officers used excessive force against Appellant after he was removed from his vehicle.Plaintiff, a black man, was stopped by two police officers. The stop escalated into a physical altercation during which five police officers forcibly removed Plaintiff from the vehicle and wrestled him to the ground. Plaintiff was convicted of several offenses stemming from the incident. While the criminal case was pending, Plaintiff filed a civil action alleging that the officers committed several torts and violated his civil rights. The trial court granted summary judgment for Defendants on the civil action. The Supreme Judicial Court vacated the judgment in part, holding (1) Plaintiff's civil action may only proceed where it is based on facts beyond those that were necessary to sustain Plaintiff's prior criminal conviction and where Plaintiff demonstrates that his claims would not necessarily challenge the validity of his prior criminal conviction; and (2) this conclusion does not bar the claims that Plaintiff based on events that occurred after the police officers forcibly removed him from his vehicle. View "Tinsley v. Town of Framingham" on Justia Law

The Supreme Judicial Court established a revised test for a court to determine whether a defendant seeking to suppress evidence based on a claim that a traffic stop violated equal protection principles.The Supreme Judicial Court reversed the judgment of the district court denying Defendant's motion to suppress the evidence seized from the vehicle he was driving, holding that the trial judge abused his discretion in denying the motion to suppress because Defendant produced sufficient evidence to raise a reasonable inference that the stop was racially motivated. In so holding, the Court concluded (1) a defendant seeking to suppress evidence evidence based on a violation of his or her equal protection rights must establish a reasonable inference that the officer's decision to initiate the stop was motivated by race or another protected class; and (2) to raise this inference, the defendant must point out specific facts from the totality of the circumstances surrounding the stop. View "Commonwealth v. Long" on Justia Law