Justia Massachusetts Supreme Court Opinion Summaries

In this case, a Superior Court judge in Massachusetts sought guidance from the Supreme Judicial Court on three questions involving the pretrial confinement of a juvenile charged with murder. The juvenile, who was sixteen years old when he was charged with second-degree murder, was initially held without bail at a Department of Youth Services (DYS) facility due to a "courtesy" arrangement with the county sheriff. As the juvenile neared his eighteenth birthday, he was informed that he would be moved to an adult facility. In response, a Superior Court judge released him on personal recognizance on the murder charge and set bail on a related non-murder charge, ordering that he stay at the DYS facility.The Supreme Judicial Court of Massachusetts was asked to determine: 1) whether a Superior Court judge can commit a person under age eighteen charged with murder to DYS's care as a pre-trial detainee; 2) if not, can a Superior Court judge set bail on a charge related to, but other than murder, so that the person under eighteen is not held on bail on the murder charge and is committed to DYS's care; and 3) if the answers to questions 1 and 2 are "No," is the last paragraph of G. L. c. 119, § 68 (which mandates that juveniles charged with murder be committed to the custody of the sheriff) unconstitutional?The Supreme Judicial Court declined to answer the third question due to mootness, as the defendant had since turned eighteen and pleaded guilty to manslaughter. Regarding the first two questions, the court referred to its previous ruling in Nicholas-Taylor v. Commonwealth and affirmed that a Superior Court judge does not have the authority to commit a juvenile defendant charged with murder to the custody of DYS, nor can they sidestep this requirement by committing the juvenile to DYS on a related non-murder offense. Therefore, the answers to the first and second questions were "No." View "Commonwealth v. Padilla" on Justia Law

In a case before the Supreme Judicial Court of Massachusetts, the defendant, Elvio Marrero, was convicted of the murder of Pernell Kimplin based on evidence that included bloodstains on Marrero's leather jacket. The bloodstains were used by the prosecution to link Marrero to the crime and to support the testimony of a key witness. However, twenty years after the trial, DNA testing showed that the blood on the jacket did not belong to the victim. Marrero's motion for a new trial, based on these DNA test results, was initially denied by a lower court, but the Supreme Judicial Court disagreed with that decision. The court found that the bloodstains were the strongest piece of physical evidence linking Marrero to the murder, and were used by the prosecution to corroborate the testimony of a key witness with credibility issues. As such, the court held that the bloodstains on the jacket likely played a significant role in the jury's deliberations. The court concluded that, had the new DNA test results been available at the time of the trial and the prosecution had been unable to connect the bloodstains to the murder, there is a substantial risk that the outcome of the trial would have been different. Therefore, the court vacated Marrero's conviction and remanded the case for a new trial. View "Commonwealth v. Marrero" on Justia Law

In this case, the defendant, Jason Robinson, was convicted of first-degree murder on a joint venture theory of felony-murder, with armed robbery as the predicate offence, in connection with the shooting death of Inaam Yazbek. Robinson appealed his convictions and the denial of his motion for a new trial, claiming insufficient evidence and trial errors.The Supreme Judicial Court of Massachusetts affirmed Robinson's conviction of murder in the first degree and the order denying his motion for a new trial. The court held that there was sufficient evidence to convict Robinson of felony-murder, as there was enough to permit an inference that Robinson knew that his co-defendant was armed during the commission of the armed robbery.The court also found no error in the admission of certain evidence, rejected Robinson's claim that he was prejudiced by being tried with his co-defendant, and found no error in the jury instructions, the exclusion of certain third-party culprit and police failure to investigate evidence, or in the prosecutor's opening statement and closing argument.However, the court ruled that Robinson's sentence of life without the possibility of parole was unconstitutional because he was nineteen years old at the time of the offense. The case was remanded for re-sentencing in line with the court's decision in Commonwealth v. Mattis. View "Commonwealth v. Robinson" on Justia Law

In this Massachusetts case, the defendant, Nyasani Watt, was convicted of first-degree murder and related offenses. After his conviction was affirmed by the Supreme Judicial Court of Massachusetts, he filed a motion for a new trial, alleging that his trial counsel had slept during critical portions of the trial, thus depriving him of his constitutional right to counsel. This motion was denied by a lower court judge without a hearing, and the denial was appealed to the Supreme Judicial Court.The Supreme Judicial Court determined that Watt had presented a new, substantial issue that it could not have considered in its previous review - namely, that his trial counsel had been sleeping during significant parts of the trial.Upon reviewing the evidence, which included affidavits from several people who had observed the trial counsel sleeping, the Court found that the trial counsel did indeed sleep through a significant portion of the trial and possibly during an important aspect of the trial. The Court held that this constituted a constructive deprivation of Watt's right to counsel under Article 12 of the Massachusetts Declaration of Rights.The Court further ruled that this error created a substantial risk of a miscarriage of justice and thus the defendant's convictions were vacated, the verdicts were set aside, and the matter was remanded to the Superior Court for a new trial. View "Commonwealth v. Watt" on Justia Law

In the case before the Supreme Judicial Court of Massachusetts, the defendant, Sheldon Mattis, was convicted of first degree murder among other charges, and was sentenced to a mandatory term of life in prison without the possibility of parole. At the time of the murder, Mattis was eighteen years old. He appealed his sentence, arguing that it was unconstitutional as applied to him because he was an "emerging adult" (defined in this case as eighteen, nineteen, or twenty years old at the time of the crime), and should be entitled to the same protection as juvenile offenders, who receive a term of life with the possibility of parole.The court considered whether their previous ruling in Diatchenko I, which concluded that sentencing a juvenile to life without parole in any circumstance would violate the Massachusetts Declaration of Rights, should be extended to apply to emerging adults. The court reviewed scientific evidence showing that the brains of emerging adults are not fully mature and are similar to those of juveniles, and also considered the treatment of emerging adults in Massachusetts and elsewhere.The court concluded that a sentence of life without the possibility of parole for emerging adult offenders violates the Massachusetts Declaration of Rights. As a result, the court invalidated the provisions of Massachusetts law that deny the possibility of parole to emerging adults. The court remanded the matter to the lower court for resentencing consistent with the court's opinion. The court also noted that this ruling does not suggest that emerging adults receiving the benefit of resentencing should be paroled once they have served a statutorily designated portion of their sentences. Instead, the parole board should evaluate the circumstances surrounding the commission of the crime, including the age of the offender, together with all relevant information pertaining to the offender's character and actions during the intervening years since conviction. View "Commonwealth v. Mattis" on Justia Law

In the case at hand, the defendant, Joshua Hart, and his girlfriend, Brittany Smith, entered the home of an elderly couple, Thomas Harty and his wife, Joanna Fisher, intending to steal their car and money. The couple ended up fatally attacking both Harty and Fisher, and then fled the state in the victims' vehicle. Hart was convicted on two counts of first-degree murder, and he appealed on several grounds.Hart argued that his confession to law enforcement was involuntary and should have been suppressed, but the Supreme Judicial Court of Massachusetts disagreed. The court found that Hart's confession was voluntary based on the circumstances of the interrogation, his experience with the criminal justice system, and his own actions and statements during the interrogation.Hart also argued that the trial should have been moved to another venue due to pretrial publicity. The court disagreed, stating that the defendant did not provide sufficient evidence to demonstrate that the pretrial publicity caused either presumptive or actual prejudice. The court found that less than 20% of potential jurors were excused due to pretrial publicity, and the judge took extensive steps to protect Hart's right to a fair trial.Hart further contended that a statement made by the deceased victim, Fisher, to her nurse, which was relayed to the jury through the nurse's testimony, should have been excluded from evidence as it was hearsay and violated his right to confront witnesses. The court determined that Fisher's statements were non-testimonial and thus did not violate the confrontation clause. The court also found that even if Fisher's statements were admitted in error, there was no prejudice because the Commonwealth presented other compelling evidence of the facts relayed in Fisher's statements.Finally, Hart argued that his sentences of life without the possibility of parole constituted cruel or unusual punishment because he was under 25 years old at the time of the crimes. The court rejected this argument, finding no reason to extend the prohibition of life sentences without parole for juveniles to individuals under the age of 25.Accordingly, the court affirmed Hart's convictions. View "Commonwealth v. Hart" on Justia Law

In the case before the Supreme Judicial Court of Massachusetts, defendant Amadi Sosa was convicted of murder in the first degree, armed assault with the intent to rob, and unlawful possession of ammunition in connection with the shooting death of William Serrano. The defendant appealed his convictions and the denial of his motion for a new trial, alleging several errors, including that the trial judge wrongfully denied his motion for relief from a joint trial with his co-defendant, Julio Brian Leiva, and that the judge erroneously allowed the prosecutor to use an unauthenticated video recording during the trial. The court affirmed the defendant's convictions of murder in the first degree and armed assault with the intent to rob, and the denial of his motion for a new trial. However, the court vacated the defendant's conviction of unlawful possession of ammunition due to an error in the jury instructions. The court found that there was no reversible error with respect to the defendant's convictions of murder in the first degree and armed assault with the intent to rob, and declined to exercise its authority under G. L. c. 278, § 33E to grant relief or order a new trial. View "Commonwealth v. Sosa" on Justia Law

In the case of Commonwealth vs. William Omari Shakespeare, the defendant, Shakespeare, was convicted of murder in the first degree and related firearms offenses for the shooting death of Marcus Hall. Following the conviction, Shakespeare filed an appeal arguing that the evidence pointing to his guilt was insufficient and that the judge erred in not allowing the grand jury testimony of a deceased individual, Mark Edwards, who was present at the scene, to be admitted as evidence. Shakespeare also claimed that the police officer’s testimony about his observations of the video evidence was improperly admitted and that his trial counsel was ineffective.The Supreme Judicial Court of Massachusetts found that the evidence was sufficient for the conviction of murder in the first degree, however, the court concluded that it was an error to prohibit the admission of Edwards's grand jury testimony, which could have supported Shakespeare's defense that Edwards was the actual shooter. The court found that such error was not harmless beyond a reasonable doubt. Consequently, the court reversed all of Shakespeare's convictions and remanded the case for a new trial.The court also ruled that the officer's testimony about his observations of the video evidence was admissible and the trial counsel was not ineffective. View "Commonwealth v. Shakespeare" 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 the denial of his application for a criminal complaint, holding that Petitioner was not entitled to extraordinary relief.Petitioner filed an application seeking a criminal complaint against Respondent on three counts. The district court refused to issue the complaint, finding that no probable cause supported the first two counts. Petitioner subsequently filed this petition seeking relief from the determination that no probable cause existed to support the first count. The Supreme Judicial Court affirmed the denial of relief, holding that Petitioner was not entitled to extraordinary relief under the circumstances. View "Davis v. Noonan" on Justia Law

The Supreme Judicial Court vacated Defendant's convictions for murder in the first degree on a theory of deliberate premeditation, argued assault with intent to murder, and assault and battery by means of a dangerous weapon, holding that the trial judge prejudicially erred when it denied defense counsel's request to conduct a voir dire examination of a key witness.On appeal, Defendant argued, among other things, that the judge erred in denying his request to conduct a voir dire examination of a key prosecution witness when defense counsel received an anonymous text message suggesting that a witness had falsely identified Defendant as part of a plot to frame him. The Supreme Court vacated Defendant's convictions, holding that the judge erred in denying defense counsel's request to conduct a voir dire examination of the key identification witness, and the error was prejudicial. View "Commonwealth v. Troche" on Justia Law