Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court dismissed Plaintiff's complaint seeking relief in the nature of mandamus, holding that mandamus relief did not lie with respect to Plaintiff's challenges to discretionary decisions of the superior court.Plaintiff's requests for relief related to postconviction motions and other requests Plaintiff made in a criminal proceeding in the superior court to withdraw his guilty plea. Plaintiff requested several clarifications and that the Court provide a "speedy remedy" for other alleged instances of inaction or misconduct by the superior court in failing to provide relief. The Supreme Judicial Court denied relief, holding that Plaintiff failed to make a showing that alternative avenues of relief were inadequate. View "In re Burnham" on Justia Law

The Supreme Judicial Court affirmed the judgment of a single justice of the court denying Petitioner's petition for extraordinary relief under Mass. Gen. Laws ch. 211, 3, holding that the single justice neither erred nor abused her discretion in denying relief.Petitioner primarily sought relief from a superior court judgment revoking his probation and imposing a suspended sentence. In his petition, Petitioner argued that the superior court's reliance on his mental health issues and treatment in refusing to re-probate him violated the Federal Americans with Disabilities Act. The single justice denied relief. The Supreme Judicial Court affirmed, holding that Petitioner's claims were appropriately raised in a direct appeal from the revocation of his probation. View "Burnham v. Commonwealth (No. 1)" on Justia Law

In this case regarding the mitigation of the spread of COVID-19 in the Commonwealth's prison decision the Supreme Judicial Court affirmed its prior decision, issued on April 3, 2020, as to the extent of the Court's constitutional authority to stay final sentences absent an ongoing challenge to the underlying conviction or a violation of constitutional rights, holding that the global stays of sentences sought by Petitioners would co-opt executive functions in ways that are not permitted by article 30 of the Massachusetts Declaration of Rights.Petitioners asked the Supreme Judicial Court to reconsider its determination that neither the Court's inherent judicial authority nor its superintendence authority permitted a judge to stay a final sentence that is being served, absent a pending appeal or a motion for a new trial, without violating separation of powers principles under article 30. Petitioners further challenged the court's order with respect to reporting requirements. The Supreme Judicial Court affirmed its prior decision but concluded that some of the requested relief as to additional reporting requirements should be allowed, and accordingly issued a revised Appendix B. View "Committee for Public Counsel Services v. Chief Justice of the Trial Court (No. 2)" on Justia Law

The Supreme Judicial Court affirmed the judgment of the county court denying, without a hearing, Petitioner's petition for relief under Mass. Gen. Laws ch. 211, 3, holding that the single justice did not err or abuse his discretion in denying relief.Defendant was convicted of several offenses. The Appeals Court reversed the convictions and remanded the matter for a new trial. Thereafter, the Commonwealth filed a nolle prosequi as to all the charges. In his Mass. Gen. Laws ch. 211, 3 petition, Defendant alleged that no crime had been committed and that he was wrongfully prosecuted. The single justice denied relief. The Supreme Judicial Court affirmed, holding that Defendant did not demonstrate entitlement to the exercise of this Court's superintendence powers. View "In re Mitchell" on Justia Law

The Supreme Judicial Court affirmed the judgment of a single justice of the court denying Petitioner's petition for extraordinary relief under Mass. Gen. Laws ch. 211, 3 seeking an order vacating Petitioner's plea to aggravated rape and dismissing the underlying indictment, holding that the single justice did not err or abuse his discretion in denying relief.The issues raised by Petitioner had all been raised and adjudicated through the normal appellate process. Petitioner then filed a motion to withdraw his guilty plea. The motion was denied, and the Appeals Court affirmed. In this petition for extraordinary relief, Petitioner sought an order vacating his plea to aggravated rape and dismissing the underlying indictment. The single justice denied relief. The Supreme Judicial Court affirmed, holding that the superintendence power was not available as an additional layer of appellate review once all other avenues had been exhausted. View "Garden v. Commonwealth" on Justia Law

The Supreme Judicial Court reversed the order of the superior court denying Defendant's motion for a new trial and set aside the jury's verdicts of first degree murder and robbery, holding that a recently discovered witness statement made to the police ago constituted newly discovered evidence that "would probably have been a real factor in the jury's deliberations."At issue was Defendant's sixth motion for a new trial, which was predicated on newly discovered evidence consisting of, among other things, a recently discovered statement made to the police in 1972. The superior court denied the motion. As to the police statement, the judge found that it did not constitute newly discovered evidence because Defendant failed to establish that defense counsel did not have possession of it at the time of trial. The Supreme Judicial Court reversed and remanded the case for a new trial, holding (1) Defendant sustained his burden of establishing that defense counsel did not have the 1972 police statement prior to or at trial, and therefore, the statement constituted newly discovered evidence; and (2) there was a substantial risk that the jury would have reached a different conclusion had the evidence been admitted at trial. View "Commonwealth v. Mazza" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court denying Defendant's motions to suppress, holding that the limited use of automatic license plate readers (ALPRs) in this case did not implicate constitutional protections against unreasonable searches.While police were investigating Defendant on suspicion of drug distribution they used ALPRs on two bridges to track Defendant's movements. The police accessed historical data via ALPR technology and received real-time alerts, the last of which led to Defendant's arrest. Defendant filed motions to suppress the ALPR data and the fruits of the arrest. The superior court denied the motions. The Supreme Judicial Court affirmed, holding that while the widespread use of ALPRs in the Commonwealth could implicate a defendant's constitutional protected expectation of privacy in the whole of his public movements, that interest was not invaded by the limited extent and use of the ALPR data in the instant case. View "Commonwealth v. McCarthy" on Justia Law

The Supreme Judicial Court affirmed the order of the superior court entering judgment in favor of the parole board on Plaintiff's appeal from the denial of his application for parole, holding that the board did not abuse its discretion in denying Plaintiff's application.Plaintiff was seventeen years old when he committed murder in the second degree. Plaintiff was sentenced to life imprisonment for the murder. Plaintiff later applied for parole, but the board denied the application. Plaintiff sought review, alleging that the board abused its discretion by failing properly to analyze the distinctive attributes of youth in making its determination. A superior court judge granted the board's motion for judgment on the pleadings and denied Plaintiff's cross motion for the same. The Supreme Judicial Court affirmed, holding that the board based its decision on the statutory standard of rehabilitation and compatibility with the welfare of society, and the board adequately considered the distinctive attributes of youth. View "Deal v. Massachusetts Parole Board" on Justia Law

The Supreme Judicial Court held that, due to the crisis caused by the COVID-19 pandemic, pretrial detainees who have not been charged with an excluded offense are entitled to a rebuttable presumption of release on personal recognizance and a hearing within two business days of filing a motion for reconsideration of bail and release.To decrease exposure to COVID-19 within correctional institutions, Petitioners sought the release to the community of as many pretrial detainees and individuals who have been convicted and are serving a sentence of incarceration as possible. The Supreme Judicial Court held (1) the risks inherent in the COVID-19 pandemic constitute a changed circumstance within the meaning of Mass. Gen. Laws ch. 276, 58, tenth paragraph, and the provisions of Mass. Gen. Laws ch. 276, 57; (2) any individual who is not being held without bail under Mass. Gen. Laws ch. 276, 58A and who has not been charged with an excluded offense as set forth in Appendix A to this opinion is entitled to a rebuttable presumption of release; and (3) to afford relief to as many incarcerated individuals as possible, the parole board and Department of Corrections are urged to work with the special master to expedite parole hearings and the issuance of parole permits. View "Committee for Public Counsel Services v. Chief Justice of Trial Court" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of two counts of murder in the first degree on the theory of deliberate premeditation and three related charges, holding that there was no reversible error in this case.Specifically, the Supreme Judicial Court held (1) the motion judge did not abuse his discretion in denying Defendant's motion to suppress evidence; (2) the trial judge did not abuse her discretion in admitting evidence of a document under the business records exception to the rule against hearsay; (3) the judge's failure to provide guidance to the jury regarding how it should weigh the business records constituted error, but the error did not create a substantial likelihood of a miscarriage of justice; (4) even if the judge erred in admitting testimony concerning firearms, the error would not have prejudiced Defendant; (5) the trial judge's jury instruction regarding the firearms testimony did not create a substantial likelihood of a miscarriage of justice; (6) there was no error in the prosecutor's improper statements made in his closing argument; and (7) there was no basis for reducing sentence on the murder conviction or ordering a new trial under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Andre" on Justia Law