Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed the judgment of the county court denying Petitioner's petition for relief under Mass. Gen. Laws ch. 211, 3, holding that the single justice neither erred nor abused his discretion in denying relief.Petitioner was convicted of multiple counts of larceny over $250. Petitioner's appeal was ultimately dismissed for lack of prosecution. Petitioner later filed his Mass. Gen. Laws ch. 211, 3 petition seeking an order dismissing the underlying criminal charges on the grounds that his appeal was deliberately blocked by the appeals court and others. A single justice denied relief. The Supreme Judicial Court affirmed, holding that Petitioner was not entitled to review pursuant to Mass. Gen. Laws ch. 211, 3. View "Kyricopoulos v. Commonwealth" on Justia Law

The Supreme Judicial Court affirmed the judgment of the single justice of the court denying Plaintiff's requests for declaratory relief pursuant to Mass. Gen. Laws ch. 231A, 1, holding that the single justice properly denied relief.In his petition for declaratory relief Plaintiff requested to have the judge removed from his criminal matter and sought a general declaration that the judge should not sit on any criminal matters in Bristol County. The single justice denied relief. The Supreme Judicial Court affirmed, holding (1) because Plaintiff pleaded guilty, disposing of the criminal charge, Plaintiff's request to have the judge removed from his criminal matter was moot; and (2) Plaintiff had no right as a matter of law to seek an order compelling a judge's recusal from any case other than his own. View "Murphy v. Superior Court" on Justia Law

The Supreme Judicial Court affirmed the judgment of a single justice denying Defendant's Mass. Gen. Laws ch. 211, 3 petition for bail review, holding that because the bail determinations were properly made and no violation of Defendant's rights occurred, the single justice did not err or abuse her discretion in denying Defendant's petition seeking review of the bail determination.Defendant's first trial for murder in the first degree and ended in a mistrial. Defendant subsequently filed a motion to dismiss the indictment on double jeopardy grounds, but the motion was denied. A single justice denied Defendant's Mass. Gen. Laws ch. 211, 3 petition seeking review of that ruling, and the Supreme Judicial Court affirmed. While Defendant's appeal was pending, bail was set in the cash amount of $250,000. After Defendant unsuccessfully filed a motion for bail review he filed a petition pursuant to Mass. Gen. Laws ch. 211, 3 for bail review. A single justice denied the petition. The Supreme Judicial Court affirmed, holding that the single justice did not err or abuse her discretion in denying the petition. View "Pinney v. Commonwealth" on Justia Law

The Supreme Judicial Court held that possession of an open container of alcohol in a motor vehicle is a civil motor vehicle infraction rather than a criminal offense, thus overruling Commonwealth v. Giannino, 371 Mass. 700 (1977), in which the Court held that automobile law violations must encompass the "operation or control" of a motor vehicle.Defendant was charged with possessing open container of alcohol in a motor vehicle in violation of Mass. Gen. Laws ch. 90, 20, and other offenses. Defendant argued that the open container charged constituted a civil infraction, rather than a criminal offense. The trial court disagreed, concluding that it was a criminal offense. A jury found Defendant guilty. At issue was whether an open container violation fits within the definition of a "civil motor vehicle infraction," which is defined as an automobile law violation for which the maximum penalty does not provide for imprisonment. The Supreme Court affirmed after analyzing the legislative history and plain language of the open container statute, holding that a violation of Mass. Gen. Laws ch. 90, 24I is an automobile law violation and thus a civil motor vehicle infraction. View "Commonwealth v. Mansur" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree, aggravated assault and battery by means of a dangerous weapon and armed assault in a dwelling house, holding that there was no Brady violation and that the superior court judge did not err in denying Defendant's second motion for a new trial without an evidentiary hearing on the matter.On appeal, Defendant argued, among other things, that newly discovered evidence of later contradictory testimony by the Commonwealth's key witness proved that the prosecution failed to disclose a plea agreement at the time of trial in violation of Brady v. Maryland, 373 U.S. 83 (1963). The Supreme Judicial Court affirmed and declined to exercise its authority under Mass. Gen. Laws ch. 278, 33E to reduce or set aside the verdict on the murder conviction, holding (1) the judge did not err in finding that Defendant's evidence of a Brady violation did not create a substantial issue warranting an evidentiary hearing; (2) the judge did not abuse his discretion in finding that there was no undisclosed plea deal that would require granting Defendant's second motion for a new trial; and (3) the verdict of murder in the first degree is consonant with justice. View "Commonwealth v. Upton" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions of murder in the first degree and related crimes, holding that Defendant was not deprived of a meaningful defense due to the current law on criminal responsibility and that there was no reason to reduce the verdict under Mass. Gen. Laws ch. 28, 33E.At trial, defense counsel unsuccessfully claimed that a mental disorder caused Defendant to suffer delusions that compelled him to plan and commit the murder. On appeal, however, Defendant argued that the law on criminal responsibility made this defense not viable. Therefore, he argued he was deprived of a meaningful defense. The Supreme Judicial Court affirmed, holding (1) the trial judge did not commit reversible error by denying two motions filed by Defendant that advocated for a departure from the current la regarding the defense of a lack of criminal responsibility; and (2) while Defendant suffered from a qualifying mental disorder, he was nonetheless able to conform his actions to the law and to understand the wrongfulness of his actions. View "Commonwealth v. Loya" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court allowing Defendant's motions to suppress evidence seized during an inventory search of his vehicle and his subsequent statements to police, holding that, where officers are aware that a passenger lawfully could assume custody of a vehicle, it is improper to impound the vehicle without first offering this option to the driver.Defendant, the driver of the vehicle in this case, was properly stopped for a motor vehicle violation and then arrested on an outstanding warrant. The vehicle's sole passenger was a duly licensed and qualified driver. The officers arranged for the vehicle to be impounded without inquiring of Defendant as to whether he preferred to have the passenger take custody of and move the vehicle. After conducting an inventory search the officers discovered Defendant's gun. The motion judge suppressed the gun and Defendant's statements, finding the impoundment to be unreasonable. The Supreme Judicial Court affirmed, holding that suppression was appropriate under the circumstances of this case. View "Commonwealth v. Goncalves-Mendez" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions entered by the trial court after a second trial, at which Defendant had different counsel, holding the second trial judge did not err in granting Defendant's motion for a new trial on the basis that Defendant's second attorney provided ineffective assistance of counsel.Defendant was charged with murder in the first degree and related offenses. Then the jury was unable to reach a verdict Defendant's first trial ended in a mistrial. The second trial resulted in Defendant being convicted. Defendant then filed a motion for a new trial, arguing that successor counsel's failure to call or investigate an alibi witness constituted constitutionally ineffective assistance of counsel. The second trial judge allowed the motion, determining that the testimony necessarily would be important to the jury's deliberations. The Supreme Judicial Court affirmed, holding that, under the circumstances, the judge was not unreasonable in finding successor counsel's performance ineffective, and the error was prejudicial. View "Commonwealth v. Diaz Perez" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions of discharging a firearm within 500 feet of a building, in violation of Mass. Gen. Laws ch. 269, 12E, and unlawful possession of a firearm, in violation of Mass. Gen. Laws ch. 269, 10(h), holding that that section 12E does not require any mens rea as to the element of discharge and that the trial judge properly declined to instruct on an exemption for temporarily holding a firearm.Defendant's convictions stemmed from an incident in which, while showing a firearm to one of his friends, Defendant accidentally discharged it in a home, shooting his friend through the hand. On appeal, Defendant argued that section 12E includes a mens rea requirement and that the trial judge erred in declining to instruct on an exemption for temporarily holding a firearm. The Supreme Court affirmed, holding (1) section 12E does not require any mens rea as to the element of discharge; and (2) the trial judge did not err in declining to give the requested instruction on the exemption for temporary possession. View "Commonwealth v. Kelly" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of assault and battery causing serious bodily injury, holding that there was no error with respect to the seating of a blind individual on the jury and that the evidence was sufficient to support the conviction.Defendant's conviction stemmed from an incident in which Defendant, without warning, punched the victim in the face. On appeal, Defendant argued, among other things, that his right to a fair and impartial jury was violated because the blind juror that served on the jury was unable to see the physical evidence and had to have the documentary evidence read to him. The Supreme Judicial Court affirmed, holding (1) seating the blind juror was not an abuse of the trial judge's discretion; and (2) the evidence was sufficient to establish beyond a reasonable doubt that Defendant caused serious bodily injury to the victim. View "Commonwealth v. Heywood" on Justia Law