Justia Massachusetts Supreme Court Opinion Summaries

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

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