Justia Massachusetts Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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The Supreme Judicial Court affirmed the decision of a single justice of the court denying Petitioner's petition pursuant to Mass. Gen. Laws ch. 211, 3 seeking review of a Housing Court judge's order denying his motion for waiver of an appeal bond, setting the bond, and ordering payment of use and occupancy during the pendency of Petitioner's appeal from an adverse summary process judgment, holding that the single justice neither erred nor abused her discretion.Petitioner sought and received review of the Housing Court judge's order from a single justice of the Appeals Court. In challenging the order, Petitioner neither appealed to the Appeals Court from the dismissal of his summary process appeal, nor did he raise his claims concerning the bond and the use and occupancy payments in the direct appeal from the summary process judgment in the Appeals Court. Because Petitioner had other adequate and effective routes to seek relief, the Supreme Judicial Court held that the single justice properly denied relief under Mass. Gen. Laws ch. 211, 3. View "Perry v. U.S. Bank Trust, N.A." on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court affirmed the decision of a single justice of the court treating Petitioner's requests for declaratory, injunctive, and other relief concerning certain inmate mail regulations as a petition pursuant to Mass. Gen. Laws ch. 211, 3 and denying relief, holding that the single justice neither erred nor abused her discretion.Specifically, the Supreme Judicial Court held (1) Petitioner's memorandum filed pursuant to S.J.C. Rule 2:21, as amended, did nothing to establish the inadequacy of the ordinary process of trial and appeal; and (2) the single justice acted within her discretion in concluding that there was no reason to exercise the court's extraordinary authority to grant the preliminary injunction or otherwise grant the relief requested by Petitioner in the first instance. View "Snell v. Superintendent, Massachusetts Correctional Institute, Shirley" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court affirmed Defendant's conviction for murder in the first degree on the theory of extreme atrocity or cruelty, holding that the trial court did not abuse its discretion in ruling that Defendant's statements made to his doctors before and after the murder regarding his mental health were not admissible for their truth.On appeal, Defendant argued that the trial judge erred in ruling that Defendant's statements to two doctors about his mental health were not admissible substantively and that the judge's instruction to the jury that they could not consider such statements for the truth of the matter was incorrect as a matter of law. The Supreme Judicial Court disagreed and affirmed, holding (1) the judge did not err in ruling that the statements Defendant made to the doctors were not admissible for the truth of the matter or in instructing the jury to that effect; and (2) there was no reason for the Court to exercise its authority under Mass. Gen. Laws ch. 278, 33E to grant a new trial or to reduce or set aside the verdict of murder in the first degree. View "Commonwealth v. Rodriguez" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court affirmed the judgment of the county court denying, without a hearing, the Commonwealth's petition for relief under Mass. Gen. Laws ch. 211, 3 from an order of the municipal court, holding that the single justice did not abuse his discretion in denying the Commonwealth's petition without reaching the merits.Defendant was charged with drug possession after a confidential informant, working under the direction of the police department, carried out three controlled purchases of a substance believed to be heroin. Under information obtained in these controlled purchases, the police obtained a warrant to search Defendant's apartment. The search led to Defendant's arrest. Defendant filed a motion for rewards and promises under Mass. R. Crim. P. 14(a)(1)(C) seeking information concerning the police department's dealings with the confidential informant. The judge allowed the motion in part, finding that the information was necessary to prepare a defense. The Commonwealth filed its Mass. Gen. Laws ch. 211, 3 petition. The single justice denied relief. The Supreme Judicial Court affirmed, holding that the Commonwealth did not show that the petition presented an exceptional circumstance requiring the exercise of the court's extraordinary superintendence power. View "Commonwealth v. Rodriguez" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court affirmed the judgment of a single justice of the court dismissing John Doe's complaint for declaratory and injunctive relief, relief in the nature of mandamus, equitable relief, and extraordinary relief under Mass. Gen. Laws ch. 211, 3 seeking relief of the obligation to register with the Sex Offender Registry Board (Board), holding that the single justice did not err or abuse his discretion in denying relief.In denying Doe's request to be relieved of the obligation to register with the Board, the single justice noted that Doe had an adequate alternative avenue to obtain relief by way of a request to the Board to be terminated and to have an evidentiary hearing where he may be represented counsel. The Supreme Judicial Court affirmed, holding that the single justice properly denied relief. View "Doe, Sex Offender Registry Board No. 21634 v. Sex Offender Registry Board" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court affirmed the judgment of a single justice of the court granting the Commonwealth's petition under Mass. Gen. Laws ch. 211, 3 and ordering that a certain superior court judge be recused from acting on Defendant's postjudgment motion to dismiss the indictments against him or for a new trial in his criminal case, holding that the single justice did not err or abuse her discretion.Defendant was convicted of murder in the first degree. The Supreme Judicial Court remanded the case for consideration of whether Defendant was prejudiced by trial counsel's potential conflicts of interest. On remand, Defendant moved to dismiss the indictments against him or for a new trial on the basis of Brady violations. The motion judge raised the question whether she could be impartial because the prosecutor had since been appointed as a superior cour judge and was now her judicial colleague. The Commonwealth subsequently filed a motion in support of recusal. The judge denied the motion, concluding that she could be fair and impartial. The Commonwealth filed a Mass. Gen. Laws ch. 211, 3 petition. A single justice allowed the petition. The Supreme Judicial Court affirmed, holding that the prudent and legally correct result under the circumstances was for the judge to recuse herself. View "Commonwealth v. Cousin" on Justia Law

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In this appeal challenging Appellant's classification before the Sex Offender Registry Board (Board) as a level three sex offender, the Supreme Judicial Court remanded the matter, holding that once a hearing examiner has allowed a motion for expert funds to a sex offender seeking a review hearing on his classification, expert testimony in a board hearing is admissible unless it is irrelevant, unreliable, or repetitive.After the Board notified Appellant of his duty to register Appellant requested his statutory right to a review of his classification by one of the Board's hearing examiners. Before the hearing, Appellant, who was indigent, moved for expert funds to hire an expert in forensic psychology and assessing sex offenders' risk of reoffense. The hearing examiner granted the motion but, during the hearing, significantly limited the expert's testimony. On appeal, the superior court affirmed. The Supreme Judicial Court remanded the matter to the Board for a new hearing at which Appellant's expert may testify as to any relevant, reliable, and nonrepetitive evidence, holding that the hearing examiner improperly limited the scope of Appellant's expert's testimony. View "Doe, Sex Offender Registry Board No. 234076 v. Sex Offender Registry Board" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on theories of deliberate premeditation and extreme atrocity or cruelty and declined to exercise its power pursuant to Mass. Gen. Laws ch. 278, 33E to reduce the conviction to manslaughter, holding that there was no reversible error in the proceedings below.Specifically, the Supreme Judicial Court held (1) the trial judge did not err by denying Defendant's requests for a jury instruction pursuant to Commonwealth v. Croft, 345 Mass. 143 (1962); (2) the trial judge did not err by denying Defendant's motions for a required finding of not guilty under Croft because a rational jury could have found that Defendant was guilty of murder in the first degree on both the theories of premeditation and extreme atrocity or cruelty; and (3) there was no basis for reducing Defendant's sentence or ordering a new trial. View "Commonwealth v. Tavares" on Justia Law

Posted in: Criminal Law
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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. 278E to reduce Defendant's conviction to murder in the second degree, holding that Defendant was not entitled to relief on any of his allegations of error.Defendant was convicted of murder in the first degree on the theory of felony-murder. Defendant filed a motion for a new trial, which was denied. The Supreme Judicial Court affirmed, holding (1) Defendant's motion for a new trial was correctly denied because Defendant was not prejudiced by counsel's ineffective assistance; (2) this Court declines to extend the reach of the Court's holding in Commonwealth v. Brown, 477 Mass. 805 (2017), to Defendant's case; and (3) trial judge erred when he declined Defendant's request that the jury be instructed on the elements of voluntary and involuntary manslaughter, but the error was not prejudicial in the context of the judge's other instructions. View "Commonwealth v. Martin" on Justia Law

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The Supreme Judicial Court affirmed Defendant's convictions and the decision of the Appeals Court denying Defendant's motion to vacate the entry of his appeal from his convictions in that court and to have the case entered directly in the Supreme Judicial Court, holding that a direct appeal from the third conviction of a habitual offender pursuant to Mass. Gen. Laws ch. 279, 25(b) may be entered in the Appeals Court.Defendant was indicted for serious felonies arising from a brutal attack and rape. In addition to charging the specific felony, each indictment also alleged that the sentence for that felony should be enhanced pursuant to the habitual criminal provision Mass. Gen. Laws ch. 279, 25(a) or the habitual offender provision of section 25(b), or both. After he was convicted, Defendant moved to have the case entered directly in the Supreme Judicial Court. The Appeals Court denied the motion. The Supreme Judicial Court affirmed Defendant's convictions, holding (1) this direct appeal was entitled to the unique review prescribed by Mass Gen. Laws ch. 278, 33E, and the Appeals Court may conduct such section 33E review; (2) Defendant was not impermissibly allowed to waive his right to a jury trial on the sentencing enhancement provisions of the indictments; and (3) Defendant was not entitled to reversal of his convictions on any other ground. View "Commonwealth v. Billingslea" on Justia Law