Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial court affirmed the district court judge’s order allowing Defendant’s motion to suppress narcotics seized from Defendant’s crotch area as a result of a strip search that took place in a cell at a police station, holding that police did not have probable cause to believe that Defendant had concealed narcotics somewhere on his person so as to justify conducting a strip search.Specifically, the Court held that, based on the facts of this case, the officers had, at best, a reasonable suspicion that Defendant could be concealing contraband in his crotch, but because there was no affirmative indication that Defendant was secreting contraband in his groin area, the police lacked probable cause to conduct a strip search of Defendant. View "Commonwealth v. Agogo" on Justia Law

The Supreme Court affirmed the trial court’s grant of Defendant’s motion to suppress in this case concerning the scope of the emergency aid exception and the exigent circumstances exception to the warrant requirement.Defendant filed a motion to suppress evidence seized pursuant to a warrant on the ground that the warrant was predicated on observations made during an unconstitutional warrantless search. The superior court allowed the motion. The appeals court reversed, concluding that the warrantless search was permissible under the emergency aid doctrine. The Supreme Court granted further appellate review and affirmed the order allowing the motion to suppress, holding (1) the warrantless search was not justified under the emergency aid exception; and (2) the search was not justified under the probable cause and exigent circumstances exception. View "Commonwealth v. Arias" on Justia Law

The Supreme Judicial Court held that the common-law doctrine of abatement ab initio, where a criminal conviction is vacated and the indictment is dismissed after the defendant dies while his direct appeal as of right challenging that conviction is in process, is outdated and that a new approach that is more consonant with the circumstances of contemporary life applies in the present case.In this case, the defendant may have committed suicide to prevent the application of the doctrine of abatement ab initio to benefit surviving family members, heirs, and other beneficiaries. The Supreme Judicial Court reversed the trial court’s order allowing Defendant’s motion to abate prosecution, dismissing Defendant’s notice of appeal, vacating his conviction, and dismissing the indictment and dismissing Defendant’s notice of appeal as moot. The Court held (1) when a defendant dies irrespective of cause while a direct appeal of right challenging his conviction is pending, the proper course is to dismiss the appeal as moot and note in the record that the conviction removed the defendant’s presumption of innocence but that the conviction was neither affirmed nor reversed on appeal because the defendant died; and (2) this approach, which otherwise applies only prospectively, should apply in the instant case. View "Commonwealth v. Hernandez" on Justia Law

The Supreme Judicial Court reversed the trial judge’s denial of the Commonwealth’s renewed motion filed pursuant to Commonwealth v. Gelfgatt, 468 Mass. 512 (2014), and remanded for entry of an order compelling Defendant to enter a password into a cell phone seized from Defendant at the time of his arrest, holding that the motion judge abused his discretion in denying the Commonwealth’s motion.Defendant was charged with, among other things, trafficking a person for sexual servitude. The Commonwealth was granted a search warrant to search the cell phone found on Defendant, but the cell phone’s contents could only be accessed with the entry of a password. At issue was whether requiring Defendant to enter the cell phone’s password would violate his constitutional privilege against self-incrimination. A trial judge concluded that the Commonwealth failed to prove that Defendant’s knowledge of the password was a “foregone conclusion” under the Fifth Amendment to the United States Constitution and article 12 of the Massachusetts Declaration of Rights and denied the Commonwealth’s motion and renewed motion to compel Defendant to produce the password. The Supreme Judicial Court reversed, holding that Defendant’s knowledge of the password was a foregone conclusion and not subject to the protections of the Fifth Amendment and article 12. View "Commonwealth v. Jones" on Justia Law

The Supreme Judicial Court affirmed the judgment of a single justice denying Petitioner’s petition pursuant to Mass. Gen. Laws ch. 211, 3, holding that the single justice correctly denied the petition because there were adequate alternative routes available to Petitioner to seek and obtain review of his claims.Petitioner was convicted of possessing counterfeit currency, uttering a counterfeit note, and larceny by false pretenses of property not exceeding $250 in value. Years later, Petitioner filed this petition alleging that he received ineffective assistance of counsel at trial and on appeal and that his convictions were wrongful in several different aspects. The single justice denied relief. The Supreme Judicial Court affirmed, holding that because the errors raised in the petition either were or could have been raised on direct appeal, the single justice neither erred nor abused his discretion in denying the petition. View "Tavares v. Commonwealth" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of murder in the first degree on a theory of deliberate premeditation and of carrying a firearm without a license, holding that Defendant’s claims of evidentiary errors and improper argument during the prosecutor’s closing did not require a reversal of his convictions.Specifically, the Court held (1) the trial court did not err in admitting into evidence Defendant’s statement to the police; (2) it was error to admit certain extraneous firearm evidence, but there was not substantial likelihood of a miscarriage of justice; (3) a rhetorical question and answer in the prosecutor’s closing argument did not rise to the level of reversible error, and the prosecutor’s description of Defendant as “leader of the pack” and “Alpha dog” did not create a substantial likelihood of a miscarriage of justice; and (4) there was no basis to set aside or reduce the verdict of murder in the first degree. View "Commonwealth v. Collazo" on Justia Law

The Supreme Judicial Court affirmed Defendant’s convictions of penile-vaginal and digital-vaginal rape, holding that while two errors occurred during the trial proceedings, neither error required reversal of Defendant’s convictions.On appeal, Defendant argued (1) the judge erred by failing to instruct the jury that a defendant may not be found guilty of rape after the victim withdrew her consent after initially consensual intercourse unless the penetration continued after the victim communicated the withdrawal of consent to the defendant, and (2) the judge erred in admitting evidence of cocaine use for the purpose of allowing the jury to assess Defendant’s ability to perceive and recall events where there was no expert testimony regarding the effect of cocaine on perception and memory. The Supreme Court held that the judge erred in failing to provide the jury with an instruction regarding the withdrawal of consent and in admitting cocaine evidence for the purpose of assessing Defendant’s memory, but under the circumstances, neither error required reversal of Defendant’s convictions. View "Commonwealth v. Sherman" on Justia Law

The Supreme Judicial Court affirmed Defendant’s conviction of possession of a class B substance with intent to distribute, holding that although the voir dire in this case was incomplete, it did not prejudice Defendant.During jury selection, and over Defendant’s objection, the judge excused for cause a prospective juror who said that it was her opinion that “the system is rigged against young African American males.” On appeal, Defendant argued that the judge abused his discretion in dismissing the prospective juror. While the Supreme Court declined to set aside the verdict, the Court took the opportunity to set forth the factors a judge should consider when a prospective juror states a belief or opinion based on his or her world view. View "Commonwealth v. Williams" on Justia Law

The Supreme Judicial Court affirmed the order of the motion judge in this case allowing Defendant’s motion to suppress his postarrest statements, holding that the police lacked probable cause to arrest.Defendant was charged with receiving a stolen motor vehicle, subsequent offense, and receiving stolen property over $250 in connection with items found in a stolen motor vehicle. Defendant filed a motion to suppress his postarrest statements on the grounds that the police lacked probable cause to arrest. The motion judge allowed the motion. The Supreme Judicial Court affirmed, holding that there was insufficient evidence to establish probable cause that Defendant knew the vehicle was stolen, which is a requisite element of the crime of receiving a stolen motor vehicle. View "Commonwealth v. Pridgett" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court convicting Defendant of murder in the first degree on a theory of deliberate premeditation, holding that there was no reversible error in the proceedings below.Specifically, the Court held (1) the trial judge did not err in denying Defendant’s requests for an instruction on accident and on involuntary manslaughter; (2) the absence of an instruction on voluntary manslaughter did not create a substantial likelihood of a miscarriage of justice; (3) this Court was not required to apply the theory of transferred intent self-defense to correct a miscarriage of justice; (4) Defendant was not entitled to a new trial based on the erroneous deprivation of two preemptory challenges; (5) a police officer’s identification testimony, even if erroneous, was not prejudicial; and (6) trial counsel’s failure to present an intoxication defense through available witnesses did not constitute ineffective assistance of counsel. View "Commonwealth v. Pina" on Justia Law