Justia Massachusetts Supreme Court Opinion Summaries

In this postconviction action arising from the misconduct of chemist Annie Dookhan at the William A. Hinton State Laboratory Institute the Supreme Judicial Court affirmed the order of the postconviction court denying Defendant postconviction relief, holding that Defendants who withdrew their guilty pleas after Dookhan's misconduct was discovered but before the Court's decision in Bridgman v. District Attorney for the Suffolk District, 471 Mass. 465 (2015), are entitled retroactively to the protection of the Bridgeman sentencing cap but only if they actually were convicted of more serious charges or received a more severe sentence than at their first plea.Defendant successfully moved to withdraw his guilty plea to trafficking cocaine on the ground that Dookhan's misconduct rendered his plea involuntary. Defendant then pleaded guilty to possession with intent to distribute. After Bridgeman was decided Defendant moved to withdraw his second guilty plea. The motion was denied. The Supreme Judicial Court affirmed, holding that where Defendant negotiated his second plea agreement in the shadow of the original charges but was not convicted of more severe charges and did not receive a harsher punishment there was no violation of the principles underlying the Bridgeman sentencing cap and thus no need for a third plea or trial in order to apply Bridgeman retroactively. View "Commonwealth v. Camacho" on Justia Law

The Supreme Judicial Court affirmed the judgment of the single justice denying Petitioner's petition pursuant to Mass. Gen. Laws ch. 211, 3, in which Petitioner sought a stay of execution of sentence pending appeal, holding that Petitioner had an adequate alternative remedy.Petitioner was convicted of numerous counts of unlawful possession of a large capacity feeding device and other crimes. After he was sentenced, Petitioner filed a petition in the county court seeking to stay the execution of sentence. The single justice denied the petition. The Supreme Judicial Court affirmed, holding that the single justice did not err or abuse her discretion in denying relief because Petitioner had an adequate alternative remedy. View "Goodwin v. Commonwealth" on Justia Law

The Supreme Judicial Court vacated Defendant's conviction of murder in the first degree and remanded the case, holding that errors in the closing argument constituted a miscarriage of justice requiring that Defendant's conviction not stand.After Defendant was convicted of murder in the first degree the Supreme Judicial Court remanded the matter to the superior court, where the Commonwealth was given a choice of either vacating the conviction and retrying Defendant on the murder indictment or accepting a reduction of the verdict to manslaughter. The Commonwealth chose to pursue a new trial. After the trial, the jury again convicted Defendant of murder in the first degree. The Supreme Judicial Court again remanded the matter to the trial court, where the Commonwealth again may accept a reduction in the verdict or manslaughter or retry Defendant on the murder charge, holding that errors in the closing argument that were reprised from the first trial and newly introduced required a new trial, and this determination was reinforced by other issues that emerged on the Court's review pursuant to Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Niemic" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of armed robbery, holding that the motion judge did not err in denying Defendant's motion to suppress evidence of a showup identification but that, for showup identification procedures going forward, the officers conducting the showup will be required to provide instructions similar to those used in identifications through photographic arrays.In his appeal, Defendant argued (1) the showup identification evidence should have been suppressed because the procedure was so unnecessarily suggestive and conducive to mistaken identification that it denied him due process of law, and (2) the trial judge erred on several evidentiary rulings on eyewitness identification. The Supreme Judicial Court affirmed, holding (1) there was no abuse of discretion in the trial judge's determination that the identification procedure in this case was not unnecessarily suggestive; (2) following issuance of the prescript in this case, police are required to provide witnesses with an instruction prior to showup identification similar to those used in identifications through photographic arrays; and (3) there was no reversible error in the trial judge's evidentiary rulings on eyewitness identification. View "Commonwealth v. German" on Justia Law

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 where Petitioner had ordinary means to challenge her sentence the single justice did not err or abuse her discretion by denying extraordinary relief.Petitioner was convicted of making false Medicaid claims and of larceny by false pretenses. Before sentencing, Petitioner filed a motion requesting that the judge consider the provisions of Mass. Gen. Laws ch. 279, 6B. Petitioner was sentenced to a term of incarceration. In her Mass. Gen. Laws ch. 211, 3 petition, Petitioner argued that the judge violated section 6B by sentencing her to a term of incarceration without making the necessary findings. The single justice denied relief on the ground that Petitioner had an adequate alternative remedy. The Supreme Judicial Court affirmed, holding that Petitioner had a remedy in the ordinary appellate process. View "Kiago-Wilson v. Commonwealth" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on theories of extreme atrocity or cruelty and felony-murder and related crimes and declined to exercise its authority under Mass. Gen. Laws ch. 278, 33E, holding that there was no reason to reverse the convictions or to reduce the degree of guilt.Specifically, the Court held (1) Defendant was not deprived of his constitutional right to a competent interpreter to interpret the trial proceeding into his native language; (2) despite Defendant's arguments to the contrary, trial counsel provided effective assistance; (3) there was no error in the jury instructions as to joint venture liability, the merger doctrine, and the duty to find the highest crime proved beyond a reasonable doubt; (4) the trial judge did not abuse his discretion in making certain rulings concerning the conduct of the trial; and (5) there was no reason to order a new trial or to reduce the degree of guilt. View "Commonwealth v. Lee" on Justia Law

In this appeal from a judgment of conviction against Defendant of murder in the first degree the Supreme Judicial Court exercised its authority under Mass. Gen. Laws ch. 278, 33E to reduce the degree of guilt to murder in the second degree, holding that the interests of justice required that the degree of guilt be reduced under the circumstances of this case.A jury found Defendant guilty of murder int he first degree on theories of extreme atrocity or cruelty and felony-murder predicated on armed robbery. On appeal, Defendant challenged the trial court's denial of his motion for a new trial on grounds of ineffective assistance of counsel and the denial of his motion to reopen and reconsider that motion. The Supreme Judicial Court affirmed the judgment of the trial court as to the decisions to deny the motion for a new trial and the motion to reopen and reconsider the motion for a new trial but vacated the judgment of guilt of murder in the first degree, holding that, in the circumstances of this case, there was ground to reduce the verdict from murder in the first degree to murder in the second degree. View "Commonwealth v. Dowds" on Justia Law

The Supreme Judicial Court affirmed the judgment of a single justice of the court denying Petitioner's petition seeking review of an order of a district court judge denying his motion for relief from the requirement that he register as a sex offender, holding that the single justice properly could have concluded that the circumstances did not require the court's intervention.Petitioner pleaded guilty to possession of child pornography, which presumptively required him to register as a sex offender. Because Petitioner was not sentenced to immediate confinement he was eligible to seek relief from the registration requirement. Petitioner sought relief, but the district court denied the motion. Petitioner then filed a Mass. Gen. Laws ch. 211, 3 petition in the county court seeking relief from the judge's decision not to waive the registration requirement. The single justice denied the petition. The Supreme Judicial Court affirmed, holding that, in view of Petitioner's failure promptly to seek review under Mass. Gen. Laws ch. 211, 3, the single justice could have properly concluded that there were not exceptional circumstances that required the court to exercise its extraordinary power of general superintendence. View "Aroian v. Commonwealth" on Justia Law

The Supreme Judicial Court vacated the superior court judge's judgment concluding that the Parole Board did not abuse its discretion by denying Appellant's application for parole and applying the 1996 amendment to Mass. Gen. Laws ch. 127, 133A that increased the maximum permissible period between subsequent applications for parole from three years to five years, holding that further discovery concerning the Board's implementation of the 1996 amendment was necessary.In 1986, Appellant, then a juvenile, was convicted of murder in the first degree and sentenced to life imprisonment without the possibility of parole. After Miller v. Alabama, 567 U.S. 460 (2012), was decided, Appellant became eligible for parole. The Board denied Appellant's application for parole and applied section 133A, which prescribes parole eligibility conditions for prisoners serving life sentences. The superior court affirmed. The Supreme Judicial Court vacated the superior court's order allowing the Board's motion for judgment on the pleadings, holding (1) the Legislature intended the 1996 amendment to apply retroactively; (2) the amendment is not unconstitutional on its face; but (3) further proceedings were necessary to determine whether application of the amendment to Appellant was nonetheless unconstitutional. View "Roberio v. Massachusetts Parole Board" on Justia Law

The Supreme Judicial Court affirmed the district court judge's order denying pretrial detention, holding that a charge of indecent assault and battery on a child under the age of fourteen may not form the basis for pretrial detention under Mass. Gen. Laws ch. 276, 58A.Defendant was charged with engaging in sexual activity with a thirteen-year-old boy in violation of Mass. Gen. Laws ch. 276, 23A (statutory rape) and Mass. Gen. Laws ch. 265, 13B (indecent assault and battery on a child). Under the dangerousness statute, Mass. Gen. Laws ch. 276, 58A, a person charged with statutory rape cannot be held without conditions of release prior to trial. At arraignment, the Commonwealth sought a dangerousness hearing. The district court judge concluded that none of the charges qualified under the statute and that Defendant could not be detained without bail. The Supreme Judicial Court affirmed, holding that, contrary to the Commonwealth's contention, a charge for indecent assault and battery on a child under the age of fourteen does not render an individual eligible for pretrial detention. View "Commonwealth v. Vieira" on Justia Law