Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed Defendant's convictions of murder in the first degree on the theories of felony-murder and extreme atrocity or cruelty and declined to grant extraordinary relief pursuant to Mass. Gen. Laws ch. 278, 33E, holding that there was no reason to grant a new trial or to either reduce or set aside the verdict.Specifically, the Court held (1) Defendant failed to show actual juror prejudice by way of pretrial publicity; (2) the judge did not abuse his discretion in admitting fingerprint evidence because the evidence was properly authenticated; (3) trial counsel did not provide ineffective assistance; and (4) the prosecutor's statements during closing argument did not amount to reversible error. View "Commonwealth v. Mack" on Justia Law

The Supreme Judicial Court affirmed the superior court judge's order allowing Wayne Chapman's petition for release from civil commitment as a sexually dangerous person, holding that Defendant was not required to remain civilly committed after neither of two qualified examiners had concluded that Defendant was no longer sexually dangerous.When Chapman had approximately one month remaining until his anticipated release from prison the Commonwealth filed a petition to commit Chapman as a sexually dangerous person beyond the term of his criminal sentence under the current version of Mass. Gen. Laws ch. 123A. After trial, Chapman was found to be sexually dangerous and committed to the treatment center for an indeterminate period. Chapman then filed petitions for discharge from civil commitment under chapter 123A, section 9, including the one at issue here. Two qualified examiners offered the opinion that Chapman was no longer sexually dangerous. Chapman then moved for a discharge. The superior court judge, relying on Johnstone, petitioner, 453 Mass. 544, 553 (2009), allowed Chapman's motion. The Supreme Judicial Court affirmed, holding (1) Johnstone was correctly decided, and the principle of stare decisis counsels in favor of adherence to this settled precedent; and (2) where both qualified examiners concluded that Defendant was not sexually dangerous, discharge was appropriate. View "Chapman, petitioner" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of armed robbery and murder in the first degree and declined to exercise its authority under Mass. Gen. Laws ch. 278, 33E to reduce the verdict or to order a new trial, holding that there was no basis upon which to order a new trial or to reduce the degree of guilt.Specifically, the Court held (1) the trial judge did not abuse its discretion in allowing the jurors' request for a magnifying glass during deliberation; (2) the jury instruction on circumstantial evidence and inferences did not unconstitutionally diminish the Commonwealth's burden of proof or violate Defendant's due process rights; and (3) the trial court did not err in permitting Defendant's coworker to testify to Defendant's statement that, if he were to break into the neighbors' house, he would kill the neighbors. View "Commonwealth v. Silva" on Justia Law

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 extraordinary authority to afford relief under Mass. Gen. Laws ch. 278, 33E, holding that there was no error in the proceedings below warranting a new trial.On appeal, Defendant argued that, given his compromised medical and emotional state, the statements he made to police while he was in the hospital should have been suppressed and that the court should reduce the verdict to murder in the second degree. The Supreme Judicial Court affirmed the conviction, holding that no reversible error occurred in the proceedings below. View "Commonwealth v. Rivera" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial judge denying Defendant's motion for a new trial, holding that a defendant's waiver of his right to a jury of six persons need not be in writing as long as the trial judge ensures, by way of colloquy, that the defendant's decision to proceed is made knowingly and voluntarily.Defendant was convicted of cruelty to animals. During trial, one of the six jurors was excused from service. After conducting a colloquy, the judge found that Defendant knowingly and voluntarily waived his right to a jury of six persons, and the trial continued with five jurors. On appeal, Defendant argued that the trial judge erred in denying his motion for a new trial on the grounds that his waiver was invalid because it was not in writing pursuant to Mass. R. Crim. P. 19(b). The Supreme Judicial Court affirmed, holding that Defendant's waiver to his right to a six-person jury was valid. View "Commonwealth v. Bennefield" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of indecent assault and battery, holding that the trial judge did not abuse his discretion in denying Defendant's request that a question be posed to potential jurors about bias toward non-English speakers.Specifically, the Court held that while there may be a bias toward non-English speakers, such as Defendant, and that a thorough voir dire is necessary to ensure an unbiased jury, the trial judge did not abuse his discretion in denying Defendant's request to pose a question to the venire regarding language-related bias; (2) even if the judge erroneously admitted testimony from an investigator, there was no prejudice warranting a new trial; (3) the judge did not permit improper bolstering of the victim's credibility through the first complaint witness; and (4) the trial judge properly instructed the jury regarding the first complaint testimony. View "Commonwealth v. Espinal" on Justia Law

The Supreme Judicial Court Defendant's conviction of first degree murder and declined to exercise its extraordinary powers to grant relief under Mass. Gen. Laws ch. 278, 33E, holding (1) where a defendant facing trial on a charges of murder, sexual offenses against children, or rape requests individual voir dire on the issue of racial or ethnic prejudice and the defendant and the victim are of different such backgrounds, that request should be granted; but (2) a new trial was not required in this case.Specifically, the Court held (1) Defendant was not denied the right to a fair and impartial jury when, after members of the jury were exposed to an extraneous influence, the judge did not excuse the entire jury; (2) while the trial judge erred by partially excluding Defendant from the subsequent voir dire of the deliberating jury, Defendant was not prejudiced; (3) Defendant was not deprived of his right to a fair and impartial jury when the judge denied Defendant's request for individual voir dire on questions of ethnic bias; and (4) the judge did not abuse his discretion in certain evidentiary rulings. View "Commonwealth v. Colon" on Justia Law

The Supreme Judicial Court vacated Defendant's conviction of accessory after the fact to murder, holding that the evidence was insufficient to sustain the conviction.Defendant, who witnessed a killing, did not provide the police with a false alibi or comparable information that would exculpate the killer, a false narrative of the crime that would give the killer a defense, or false information to assist in the killer's escape. The only "aid" or "assistance" alleged in this case was that Defendant made false and misleading statements to police detectives and refused to provide them with requested telephone numbers. The Supreme Judicial Court vacated Defendant's conviction, holding (1) Defendant's false statements and refusal to cooperate did not constitute the aid or assistance necessary to find him guilty as an accessory after the fact under Mass. Gen. Laws ch. 274, 4; and (2) the evidence was insufficient as a matter of law to sustain the conviction. View "Commonwealth v. Rivera" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions of arson of a dwelling house, felony-murder in the second degree, and two counts of injuring a firefighter, holding that the evidence was sufficient to support the convictions and that, although the jury instruction on an "alternative theory" of arson was erroneous, the error did not warrant overturning the verdicts.On appeal, among other things, Defendant challenged the arson conviction, which served as the predicate for the other charges, and argued that the trial judge erred, as a matter of law, in instructing the jury on the alternative theory of arson, namely, that Defendant could be found guilty of she accidentally or negligently set the fire and then willfully and maliciously failed to extinguish or report it. The Supreme Judicial Court held (1) the evidence was sufficient to establish that Defendant specifically intended to burn the apartment building; (2) it was error to provide the supplemental instruction on arson, but the error did not require a new trial; and (3) there was no merit to Defendant's remaining arguments on appeal. View "Commonwealth v. Pfeiffer" on Justia Law

The Supreme Judicial Court reversed the decision of the Appeals Court affirmed Defendant's conviction of assault and battery as a lesser included offense of attempted murder, holding that the trial court's failure to give a nondeadly force self-defense instruction created a substantial risk of a miscarriage of justice.On appeal, Defendant argued that the trial judge erred by failing to instruct on the use of nondeadly force in self-defense. The Appeals Court affirmed, holding that Defendant was not entitled to such an instruction and, even if were entitled, the lack of such an instruction did not give rise to a substantial risk of a miscarriage of justice. The Supreme Judicial Court reversed and remanded for a new trial on that charge, holding (1) the court's failure to provide a nondeadly force self-defense instruction lowered the Commonwealth's burden to prove the absence of proper self-defense; and (2) under the circumstances of this case, the omission of such an instruction constituted reversible error. View "Commonwealth v. Abubardar" on Justia Law