Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed a single justice's denial of Appellant's motion for the appointment of counsel filed in connection with a gatekeeper application that Appellant had filed in the county court pursuant to Mass. Gen. Laws ch. 278, 33E, holding that the single justice did not abuse her discretion.Appellant, who was convicted of murder in the first degree and related charges, filed several motions for postconviction relief. The Supreme Court eventually directed a single justice of the court to consider Appellant's gatekeeper application for leave to appeal from the superior court's denial of his motion for the appointment of counsel to prepare and file a motion for forensic testing and his request to have counsel appointed for purposes of the application. The single justice denied the gatekeeper application and Appellant's request for the appointment of counsel. The Supreme Judicial Court affirmed the order denying Appellant's motion for the appointment of counsel, holding that Appellant failed to show that the single justice abused her discretion or that the denial of appointed counsel resulted in any unfairness or deprived him of meaningful access to review of his gatekeeper application. View "Commonwealth v. Monteiro" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the second degree and the order denying his motion for a new trial, holding that Defendant's sentence was constitutional and that no prejudicial error occurred in the proceedings below.Defendant, who was seventeen years of age at the time of the murder, was sentenced to a mandatory term of life imprisonment with eligibility for parole after fifteen years. The Supreme Judicial Court disagreed, holding (1) a mandatory life sentence with parole eligibility after fifteen years for a juvenile homicide offender convicted of murder in the second degree is constitutional; (2) the judge did not err in denying Defendant's motion to continue his sentence so that he could present evidence related to his juvenile status; (3) the judge did not err in denying Defendant's request to instruct the jury on accident; (4) Defendant's counsel was not ineffective for not requesting other jury instructions; and (5) the judge did not err in denying Defendant's motion to suppress the warrantless "pinging" of Defendant's cellular telephone because no evidence came from the search. View "Commonwealth v. Lugo" on Justia Law

The Supreme Judicial Court affirmed the superior court's order granting Defendant's motion to dismiss the cocaine and cash seized during a warrantless search of his residence, holding that Defendant's consent to a search of his residence did not purge the seizure from the taint of an illegal cell site location information (CSLI) search, where the consent was obtained through the use of information obtained from that search.The superior court ruled that the cash and cocaine must be suppressed because they were the fruits of unlawful police tracking of a cellular telephone through which the police obtained CLSI without a search warrant based on probable cause. The Supreme Judicial Court affirmed, holding (1) by monitoring the cell phone's CSLI, the police effectively monitored the movement of a vehicle in which Defendant was a passenger, thus giving Defendant standing to challenge the Commonwealth's warrantless CSLI search; (2) the seizure of the cocaine and cash was the direct result of information obtained from the illegal CSLI search; and (3) the Commonwealth failed to meet its burden of proving that the seizure was sufficiently attenuated from the illegal search such that it should not be deemed a forbidden fruit of the poisonous tree. View "Commonwealth v. Fredericq" on Justia Law

The Supreme Judicial Court reversed the motion judge's allowance of Defendant's motion to suppress, holding that police action causing an individual's cell phone to reveal its real-time location constitutes a search in the constitutional sense under article 14 of the Massachusetts Declaration of Rights, but, in this case, the warrantless search was supported by probable cause and was reasonable under the exigent circumstances exception to the search warrant requirement.After the police identified Defendant as the suspect in a murder case, the police contacted Defendant's cellular service provider to request the real-time location of Defendant's cell phone. They did so without a warrant. The service provider "pinged" Defendant's cell phone, which caused the cell phone to transmit its real-time GPS coordinates to the service provider. The GPS coordinates were relayed to the police, and the police were able to use that information to locate Defendant. Defendant moved to suppress the evidence as the fruit of an unlawful search. The motion judge allowed the suppression motion. The Supreme Judicial Court reversed, holding that the motion judge erred in concluding that the warrantless ping of Defendant's cell phone was not justified by exigent circumstances. View "Commonwealth v. Almonor" on Justia Law

The Supreme Judicial Court affirmed the judgment of the county court denying Appellant's complaint for relief in the nature of mandamus, holding that the single justice neither erred nor abused her discretion by denying relief.Appellant was convicted of first in the first degree. Appellant later requested from the Office of the Chief Medical Examiner (OCME) twenty-seven categories of documents concerning the medical examiner who performed an autopsy on the body of the victim. The OCME denied the request. Appellant appealed to the supervisor of records. The supervisor instructed the OCME to redact the records where necessary, provide them to Appellant, and to the extent the OCME claimed the records were exempt from disclosure, provide a response to support the exemption claim. When the OCME did not do so in a timely manner, Snell filed his complaint. The single justice denied relief. The Supreme Judicial Court affirmed, holding that where Appellant made no showing that the OCME had a clear cut duty to produce the documents or that the OCME was refusing to comply with the supervisor's instructions, Appellant failed to show that he was entitled to relief in the nature of mandamus. View "Snell v. Office of the Chief Medical Examiner" on Justia Law

In this criminal case, the Supreme Judicial Court reversed the judgment of a single justice of the court denying the Commonwealth's petition for relief pursuant to Mass. Gen. Laws ch. 211, 3 and remanded the case for entry of a judgment vacating a superior court judge's order allowing Defendant's motion in limine to exclude prior recorded testimony, holding that the judge erred in precluding the prior testimony.Here, the Commonwealth had no alternative avenue to obtain review of the judge's allowance of Defendant's motion in limine. At issue, then, was whether the Commonwealth's claim was "exceptional" for purposes of Mass. Gen. Laws ch. 3. The Supreme Judicial Court held (1) the single justice abused his discretion in determining that there were no exceptional circumstances in this case; and (2) the evidence was admissible because it satisfied the hearsay exception for prior recorded testimony and the constitutional restraints on that exception. View "Commonwealth v. Fontanez" on Justia Law

In this appeal brought by Defendant challenging his conviction of murder in the first degree on a theory of felony-murder the Supreme Judicial Court vacated Defendant's underlying felony conviction of armed robbery as duplicative, affirmed Defendant's remaining convictions, and affirmed the denial of Defendant's motion for a new trial, holding that a conviction on an underlying felony is duplicative of a felony-murder conviction, and the underlying felony must be vacated.The Supreme Judicial Court further declined 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, holding (1) Defendant failed to establish that his trial counsel provided ineffective assistance; (2) the Commonwealth did not engage in impermissible burden shifting by suggestion that Defendant had a duty to obtain or preserve evidence during a police interview; and (3) where Defendant was convicted of felony-murder in the first degree with the predicate offenses of both armed robbery and armed home invasion, a conviction on all three counts violated double jeopardy protections. View "Commonwealth v. Simon" on Justia Law

The Supreme Judicial Court reversed the motion court's order denying Defendant's motion filed under Mass. Gen. Laws ch. 278A asserting his factual innocence and requesting forensic testing of certain evidence, holding that Defendant's motion satisfied the threshold burden of Mass. Gen. Laws ch. 278A, 3(b)(4).Defendant was convicted of home invasion, armed assault in a dwelling, rape, and assault and battery. Defendant later filed a motion pursuant to chapter 278A seeking postconviction forensic and scientific testing of evidence and biological material to support a motion for a new trial. The motion judge denied the motion, concluding that Defendant's claim that no crime occurred in this case was barred from chapter 278A relief because it did not put identity at issue. The Supreme Judicial Court reversed on the basis of its opinion today in Commonwealth v. Williams, 481 Mass. __ (2019), holding that Defendant's motion satisfied the threshold burden of Mass. Gen. Laws ch. 278A, 3(b)(4) because, as stated in Williams, "a defendant who asserts that the requested testing has the potential to result in evidence that is material to his or her identity as the perpetrator of the crime because no crime in fact occurred satisfies the [section] 3(b)(4) requirement." View "Commonwealth v. Putnam" on Justia Law

The Supreme Judicial Court reversed the order of the motion judge denying Defendant's Mass. Gen. Laws ch. 278A, 3 motion, holding that Defendant, who claimed that no crime occurred, made a prima facie case for a chapter 278A request.Defendant pleaded guilty to manslaughter and unlawful possession of a firearm and ammunition. Defendant later filed this motion under chapter 278A alleging that he acted in self-defense. Defendant sought forensic testing of evidence, claiming that the testing would show that the weapon belonged to the victim and that Defendant shot the victim in self-defense. The motion judge denied Defendant's motion. The Supreme Judicial Court reversed, holding that Defendant satisfied the requirement of Mass. Gen. Laws ch. 278A, 3(b)(4) by properly asserting his factual innocence and asserting that the requested testing had the potential to result in evidence that was material to Defendant's identity as the perpetrator of the crime in the underlying case. View "Commonwealth v. Williams" on Justia Law

The Supreme Judicial Court affirmed the decision of the trial judge to grant Defendant's motion to revise and revoke his sentence to match that of his coventurer, holding that a judge may allow a defendant's motion to revise and revoke a sentence under Mass. R. Crim. P. 29(a)(2) based upon the disparity between the defendant's sentence and a coventurer's sentence subsequently imposed by a different judge.Defendant was convicted of armed robbery and other charges. Defendant received a prison sentence fo from six to eight years on the robbery count. After a separate trial before a different judge, Defendant's coventurer received a prison term of from five to seven years for armed robbery. Defendant filed a motion to revoke and revoke based on the disparity between those two sentences. The judge reduced Defendant's sentence to match the sentence of the coventurer. The Appeals Court reversed, concluding that the judge's decision was improperly based on an event that occurred after Defendant had already been sentenced. The Supreme Judicial Court granted further review and held that, under the circumstances of this case, the judge did not abuse her discretion in considering the coventurer's later-imposed sentence where the coventurer was more culpable and received a more lenient sentence. View "Commonwealth v. Tejeda" on Justia Law