Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed Defendant’s conviction of murder in the first degree on a theory of deliberate premeditation and declined to grant extraordinary relief under Mass. Gen. Laws ch. 278, 33E, holding that the prosecutor did not commit misconduct during closing argument and that the supplemental instructions provided to the jury in response to a question the jury submitted during deliberations were not in error.On appeal, Defendant argued that the prosecutor’s method of presenting grant jury testimony was flawed and that erroneous jury instructions entitled him to a reversal of his convictions. The Supreme Judicial Court disagreed, holding that the prosecutor’s method of presenting the grand jury testimony was not in error and that the instruction the judge gave in response to the jury’s question was a correct statement of the law. View "Commonwealth v. Andrade" on Justia Law

The Supreme Judicial Court affirmed the judgment of the single justice denying, without a hearing, Petitioner’s petition filed pursuant to Mass. Gen. Laws ch. 211, 3 and application for “direct appellate review” purportedly under Mass. Gen. Laws ch. 278, 33E, holding that neither the petition nor the application was the proper means for Petitioner to get the review that he sought of his conviction.After a jury trial, Petitioner was convicted of rape and of being a habitual offender. In both his petition and application, Petitioner raised issued related to the habitual offender conviction. After a single justice denied relief, Petitioner appealed. The Supreme Judicial Court held that the issues raised were ones for which Petitioner had an adequate alternative remedy by way of direct appeal, and therefore, the single justice did not err in denying both the petition and the application. View "Barbosa v. Commonwealth" on Justia Law

In this appeal from a criminal proceeding, the Supreme Judicial Court discerned no reversible error but, under the unique circumstances of this case, exercised its authority under Mass. Gen. Laws ch. 278, 33E to reduce Defendant’s conviction of murder in the first degree to murder in the second degree, holding that a conviction of murder in the second degree was more consonant with justice.Specifically, the Court held (1) the evidence was sufficient to prove that the murder was deliberately premeditated; (2) trial counsel’s error in failing to admit Defendant’s medical records in evidence did not create a substantial likelihood of a miscarriage of justice; and (3) an error in the prosecutor’s closing argument did not create a substantial likelihood of a miscarriage of justice; and (4) where there was nothing to suggest that there was any ill will between Defendant and the victim and evidence of Defendant’s intoxication, Defendant’s first-degree murder verdict is vacated and a verdict of guilty of murder in the second degree shall be entered. View "Commonwealth v. Salazar" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court judge allowing Defendant’s motion to suppress evidence that was found in plain view during a protective sweep on the basis that the officers’ entry into Defendant’s home was not justified based on exigent circumstances, holding that the judge properly found that the police created the exigency that prompted their warrantless entry into Defendant’s dwelling.Specifically, the Supreme Judicial Court held (1) article 14 of the Massachusetts Declaration of Rights provides greater protection than the Fourteenth Amendment where the police have relied on a reasonably foreseeable exigency to justify the warrantless entry into a dwelling; (2) under the circumstances of this case, the arrest of Defendant in his dwelling without a warrant was unreasonable; and (3) the Commonwealth waived the argument regarding whether, if the permissible observations from the affidavit were redacted, the search warrant was based on probable cause. View "Commonwealth v. Alexis" on Justia Law

The Supreme Judicial Court affirmed Defendant’s conviction on a single count of deriving support from prostitution under Mass. Gen. Laws ch. 272, 7, holding that Mass. Gen. Laws ch. 272, 7 is constitutional and that there was no prejudicial or other reversible error in this case.On appeal, Defendant argued that because no definition of “pimp” or “purveyor” appears in Mass. Gen. Laws ch. 272, 7, the language of the statute is unconstitutionally vague and that he was prejudiced from jury instructions tracking such language. The Supreme Judicial Court disagreed, holding (1) the statute targets those who, with the intent to profit from prostitution, live or derive support or maintenance from, or share in the earnings or proceeds of, the known prostitution of others; (2) the evidence was sufficient to support the conviction; and (3) while this Court clarifies prospectively the jury instructions, there was no prejudicial error in this case. View "Commonwealth v. Brown" on Justia Law

The Supreme Judicial Court affirmed Defendant’s convictions as a joint venturer of kidnapping and murder in the first degree and the denial of his motions for a new trial and for post trial discovery and further declined to grant extraordinary relief pursuant to Mass. Gen. Laws ch. 278, 33E, holding that Defendant was not entitled to relief.Specifically, the Court held (1) Defendant’s motion to suppress evidence obtained from his clothing was properly denied; (2) statements that the prosecutor made during closing argument regarding blood evidence connecting Defendant to the crime did not create a substantial likelihood of a miscarriage of justice; (3) Defendant did not receive ineffective assistance of counsel; and (4) there was no reason to reduce the degree of guilt or grant a new trial pursuant to the Court’s superintendence powers. View "Commonwealth v. Parker" on Justia Law

The Supreme Judicial Court affirmed Defendant’s conviction of murder in the first degree on a theory of deliberate premeditation and the denial of Defendant’s motion for a new trial, holding that no reversible error occurred in the proceedings below and that the Court had no reason to exercise its authority under Mass. Gen. Laws ch. 278, 33E to grant a new trial or to reduce or set aside the verdict.Specifically, the Court held (1) the evidence adduced at trial was sufficient to support Defendant’s convictions; (2) Defendant was not prejudiced by his inability to obtain before trial information related to the sole defense witness’s status as a confidential federal informant, and the trial judge did not abuse his discretion in declining to require the Commonwealth to secure the witness’s informant records from federal authorities and in declining to compel the testimony of federal law enforcement officers; and (3) Defendant’s trial counsel did not provide ineffective assistance. View "Commonwealth v. Ayala" on Justia Law

The Supreme Judicial Court affirmed the judgment of the single justice denying, without a hearing, Appellant’s petition for relief under Mass. Gen. Laws ch. 211, 3, holding that the superior court judge properly denied Appellant release on his personal recognizance after finding that no conditions of release would reasonably assure the safety of persons in the community.Appellant was indicted for trafficking of a personal for sexual services, deriving support from prostitution, and witness intimidation. After a dangerousness hearing in the witness intimidation case, the judge ordered that Appellant be held without bail for a period of not more than 120 days. The judge also set bail in the sex trafficking cases at $20,000. Appellant later sought a bail hearing, but no bail hearing was held at that time. Appellant then filed this petition, without success. The Supreme Judicial Court affirmed the judgment denying relief, holding that Appellant failed to show that any of the judge’s factual findings were clearly erroneous or that the judge otherwise erred or abused his discretion. View "Garcia v. Commonwealth" on Justia Law

The Supreme Judicial Court vacated the district court denial of Defendant’s motion for a new trial after he pleaded guilty to violating multiple controlled substances laws, holding that remand was required for further proceedings on Defendant’s claim of ineffective assistance of counsel because the judge might have failed to recognize his discretion to credit or discredit Defendant’s affidavits as they pertained to plea counsel’s allegedly deficient performance and failed to make factual findings about whether special circumstances relevant to the prejudice inquiry existed.After Defendant entered his plea, he filed a motion for a new trial pursuant to Mass. R. Crim. P. 30(b), arguing that his counsel had rendered ineffective assistance and that he would not have pleaded guilty if counsel had properly advised him about the plea’s immigration consequences. The motion judge denied the motion after holding a nonevidentiary hearing. The Supreme Judicial Court vacated the denial of the motion for a new trial, holding that remand was required for findings relating to the issue of plea counsel’s deficient performance and the issue of special circumstances. View "Commonwealth v. Lys" on Justia Law

The Supreme Judicial Court dismissed as moot Petitioner’s appeal from a judgment of a single justice of the court denying his petition for relief pursuant to Mass. Gen. Laws ch. 211, 3, holding that the appeal was moot in the sense that the relief Petitioner sought could no longer be granted.Petitioner, an inmate, filed a complaint seeking review of an inmate disciplinary report against him. At issue was the denial of Petitioner’s motion to amend the complaint. A single justice of the Appeals Court denied Petitioner’s petition seeking interlocutory review of the superior court judge’s denial of the motion. Petitioner then filed a petition in the county court seeking relief from the superior court’s order. After the single justice denied relief, the underlying disciplinary report was dismissed and the guilty finding was expunged from Petitioner’s administrative record. The Supreme Judicial Court dismissed as moot Petitioner’s appeal from the judgment of the single justice because the relief Petitioner sought - leave to amend his complaint - could no longer be granted. View "Hudson v. Superintendent, Massachusetts Correctional Institution, Concord" on Justia Law