Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed Defendant's convictions for murder in the first degree based on a theory of felony-murder, among other charges, holding that a police officer's identification testimony was admitted improperly, but its admission did not prejudice Defendant.On appeal, Defendant challenged the denial of his motion to suppress, among numerous other allegations of error. For the claimed errors, Defendant requested that the court reduce his verdict or order a retrial. The Supreme Judicial Court affirmed, holding (1) a police officer's testimony identifying Defendant in a video recording at trial was improperly admitted, but the admission did not prejudice Defendant; and (2) Defendant was not entitled to relief on his remaining allegations of error. View "Commonwealth v. Fisher" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions of murder in the second degree and assault and battery by discharge of a firearm but vacated his convictions for carrying a firearm without a license and carrying a loaded firearm without a license, holding that the trial judge's failure to instruct the jury that the Commonwealth was required to prove an absence of a valid license created a substantial risk of a miscarriage of justice.At trial, Defendant sought to introduce Adjutant evidence or evidence of specific incidents of violence allegedly initiated by the victim. The trial judge allowed Defendant to introduce limited evidence of violent incidents initiated by the victim. The Supreme Judicial Court vacated Defendant's convictions in part, holding (1) the judge's ruling excluding additional testimony about the violent instances initiated by the victim exceeded the cope and purpose of Adjutant evidence, but there was no prejudice from its exclusion; (2) the trial judge did not err in the instruction regarding the jury's consideration of Adjutant evidence; and (3) pursuant to this Court's decision in Commonwealth v. Guardado, 491 Mass. 666 (2023), Defendant's firearm convictions must be vacated because the judge's failure to properly instruct the jury that Defendant did not have a license to carry a firearm was not harmless. View "Commonwealth v. Souza" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of two counts of murder in the first degree on theories of deliberate premeditation, extreme atrocity or cruelty, and felony-murder on a theory of joint venture and other crimes, holding that Defendant was not entitled to relief on her allegations of error.Specifically, the Supreme Judicial Court held (1) the trial judge did not err in denying Defendant's motion for change of venue, and Defendant failed to show any actual juror prejudice from the denial or that she was tried by anything but a fair and impartial jury; (2) the evidence was sufficient to prove Defendant's guilt as a joint venturer of murder in the first degree of the first victim; (3) there was also sufficient evidence to support Defendant's conviction of the first victim on the basis of felony murder; and (4) there was ample evidence to prove Defendant's guilt as a joint venturer of murder in the first degree on the basis of deliberate premeditation of the second victim. View "Commonwealth v. Smith" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of assault and battery by means of a dangerous weapon, holding that portions of the victim's then-girlfriend's grand jury testimony were properly admitted in accordance with the hearsay exemption for prior inconsistent statements.Prior to trial, the victim's then-girlfriend Shyla Bizarro identified Defendant as the victim's attacker from surveillance video footage and testified to her identification before the grand jury. Prior to her testimony, however, Bizarro revealed that she wished to recant her statements to police and her grand jury testimony. The trial judge admitted substantively the recanted portions of Bizarro's grand jury testimony, including her prior statements of identification. The Supreme Judicial Court affirmed the conviction, holding (1) the portions of Bizarro's grand jury testimony were properly admitted as prior inconsistent statements; (2) portions of Bizarro's grand jury testimony identifying Defendant in the video independently satisfied the hearsay exemption for statements of identification; and (3) there was no merit to Defendant's remaining arguments. View "Commonwealth v. Brum" on Justia Law

The Supreme Judicial Court vacated Defendant's firearm-related convictions but affirmed his convictions for murder in the first degree based on a theory of felony-murder, home invasion and armed assault with intent to rob, holding that the firearm-related convictions must be vacated in light of Commonwealth v. Guardado, 491 Mass. 666 (2023).Specifically, the Supreme Judicial Court held (1) trial counsel was not ineffective for failing to introduce certain categories of telephone calls; (2) there was no error in the denial of Defendant's motion for a new trial; (3) Defendant's convictions of unlawful possession of a firearm and unlawful possession of a loaded firearm must be vacated in light of this Court's precedent decision in Guardado; and (4) there was no reason for this Court to exercise its extraordinary authority pursuant to Mass. Gen. Laws ch. 278, 33E to grant Defendant a new trial or reduce the murder conviction to a lesser degree of guilt. View "Commonwealth v. Gibson" on Justia Law

In this action arising from litigation between Petitioner and the mothers of his children the Supreme Judicial Court affirmed the judgment of the single justice treating the underlying petition seeking relief in the nature of certiorari as a petition under Mass. Gen. Laws ch. 211, 3 and denying the petition without holding an evidentiary hearing, holding that extraordinary relief was not warranted.In his petition, Petitioner sought correction of alleged errors in judicial proceedings, including rulings that he characterized as "gatekeeper" orders, claiming that he was precluded from seeking review of the orders because one or more of them was not timely entered on the docket of the probate and family court. The single justice denied relief. The Supreme Judicial Court affirmed, holding that Petitioner failed to carry his burden of demonstrating that adequate alternative remedies were not available to him. View "Kifor v. Commonwealth" on Justia Law

The Supreme Judicial Court affirmed the judgment of a single justice of the court denying Petitioner's petitions filed pursuant to Mass. Gen. Laws ch. 211, 3 and associated motions, holding that Petitioner was not entitled to extraordinary relief to correct errors that may be reviewed in the ordinary process of trial and appeal.Petitioner, who was indicted for rape and other charges and found incompetent to stand trial, was later determined to be competent to stand trial, and the proceedings were ongoing. In the petitions at issue, Petitioner made very general claims. The single justice declined to reach the merits of the petitions and denied relief. The Supreme Judicial Court affirmed, holding (1) the single justice did not err in denying the petitions; and (2) because this is the third time Petitioner sought extraordinary relief arising from the same criminal proceedings, Petitioner was on notice that further attempts to obtain such relief may result in the imposition of sanctions. View "Ardaneh v. Commonwealth" on Justia Law

The Supreme Judicial Court affirmed the order of a single justice of the court denying the Commonwealth's petition asking that the single justice reverse a superior court judge's order granting Defendant limited access to the alleged victim's apartment in order to prepare for trial, holding that there was no error.Defendant was charged with attempted murder and other crimes stemming from allegations that he strangled and beat the alleged victim in their shared apartment. After Defendant was provided with preliminary discovery including photographs of the alleged victim's apartment Defendant moved for access to the crime scene for defense counsel to capture additional details. The superior court judge allowed the motion, but the alleged victim denied access to certain rooms. Thereafter, the motion judge granted Defendant access to all rooms of the apartment under certain conditions. The Commonwealth then filed a petition under Mass. Gen. Laws ch. 211, 3 seeking reversal of the grant of Defendant's second motion. The single justice denied the petition. The Supreme Judicial Court affirmed, holding that there was no abuse of discretion or error of law in the denial of the Commonwealth's petition. View "Commonwealth v. Pond" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court denying Defendant's motion for a new trial following his successful motion for postconviction forensic and deoxyribonucleic acid (DNA) analysis pursuant to Mass. Gen. Laws ch. 278A, 2, holding that there was no error in the denial of Defendant's motion for a new trial.A jury convicted Defendant of murder in the first degree on a theory of extreme cruelty or atrocity, and the Supreme Court affirmed. Following multiple pro se motions, Defendant filed the instant motion for postconviction DNA analysis, which the court allowed. Defendant then filed a motion for a new trial. The motion judge denied the motion, concluding that the new evidence did not case real doubt on the justice of Defendant's conviction. Defendant then filed a petition pursuant to Mass. Gen. Laws ch. 278, 33E for leave to appeal. A single justice granted the petition. The Supreme Judicial Court affirmed the denial of Defendant's motion for a new trial, holding that Defendant was not entitled to relief on his allegations of error. View "Commonwealth v. Duguay" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions other than his unlawful possession conviction, which the Court vacated in light of its recent opinion in Commonwealth v. Guardado, 491 Mass. 666 (2023), holding that Defendant's rights under the Second Amendment and his due process rights were violated as to this conviction because the jury was not instructed that licensure was an essential element of the crime.Specifically, the Supreme Judicial Court held (1) the trial court did not err in denying Defendant's motion to suppress his statement at the police station on the grounds that police officers impermissibly recorded it without his express consent and that he was not informed promptly of his right to make a telephone call; (2) the prosecutor did not improperly refer to omissions in Defendant's statement to police officers; (3) there was no reason to reduce the degree of guilt or order a new trial; and (4) in light of this Court's recent opinion in Guardado, Defendant's unlawful possession of a firearm conviction must be vacated. View "Commonwealth v. Morris" on Justia Law