Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed the judgment of a single justice of the Court denying Petitioner’s petition pursuant to Mass. Gen. Laws ch. 211, 3, holding that the single justice did not err or abuse his discretion in denying relief.In 1974, Petitioner was convicted of several crimes in two different cases. In 2014, Petitioner filed a motion for a new trial in each of the two cases. The trial court denied the motions, and the Appeals Court affirmed. Petitioner then filed this petition raising the same issues that he had raised in the Appeals Court. The single justice denied the petition without a hearing. The Supreme Judicial Court affirmed, holding that Petitioner was not entitled to review under Mass. Gen. Laws ch. 211, 3. View "McCants v. Commonwealth" on Justia Law

The Supreme Judicial Court affirmed the judgment of a single justice of the Court denying Petitioner’s petition pursuant to Mass. Gen. Laws ch. 211, 3, holding that the single justice did not err or abuse her discretion in denying relief.Petitioner was convicted of rape of a child and indecent assault and battery on a child under fourteen years of age. Petitioner later filed his Mass. Gen. Laws ch. 211, 3 petition alleging that the trial court ignored his motion to vacate, set aside, or correct sentence that he claimed to have previously filed. The single justice denied the petition without a hearing. The Supreme Judicial Court affirmed, holding that because it was unclear from the record whether the motion was actually ever received by and filed in the trial court Petitioner was not entitled to relief. View "Santos v. Commonwealth" on Justia Law

The Supreme Judicial Court held that the widespread evidence tampering of chemist Sonja Farak at the State Laboratory Institute in Amherst at the campus of the University of Massachusetts compromised the integrity of thousands of drug convictions and that her misconduct, compounded by prosecutorial misconduct, requires that the Court exercise its superintendence authority and vacate and dismiss all criminal convictions tainted by governmental wrongdoing.Farak stole and used for her own use drugs submitted to the lab for testing and consumed drug “standards” required for testing. Members of the Attorney General’s office deceptively withheld exculpatory evidence on the matter. Petitioners sought dismissal of thousands of cases tainted by governmental wrongdoing. The Supreme Judicial Court held that the class of “Farak defendants” includes all defendants who were found guilty of a drug charge where Farak signed the certificate of analysis, the conviction was based on methamphetamine and the drugs were tested during Farak’s tenure at the Amherst lab, or the drugs were tested at the Amherst lab during a certain period regardless of who signed the certificate of analysis. The Court also recommended that the standing advisory committee on the rules of criminal procedure propose amendments to Rule 14 of the Massachusetts Rules of Criminal Procedure to include a Brady checklist and any other beneficial modifications. View "Committee for Public Counsel Services v. Attorney General" on Justia Law

At issue was the correct interpretation of Mass. Gen. Laws ch. 279, 25(a), which requires that a “habitual criminal” - or an individual who has been convicted of a felony and has two prior convictions resulting in state or federal prison sentences of three years or more - be sentenced to the maximum term provided by law on the underlying conviction.Defendant was indictment of a variety of charges. All but two of the indictments carried sentencing enhancements under 25(a). The judge allowed Defendant’s motion to dismiss the section 25(a) sentence enhancement charges, concluding that Defendant’s predicate convictions represented a single “incident” under section 25(a). The Supreme Judicial Court overruled in part Commonwealth v. Pelletier, 449 Mass. 392, 395-396 (2007), holding (1) although the predicate convictions must arise from separate incidents or episodes, the offenses need not be separately prosecuted; and (2) Mass. R. Crim. P. 15(a)(1) and Mass. Gen. Laws ch. 278, 28E grant the Commonwealth a right to appeal from the dismissal of the sentence enhancement portion of an indictment. View "Commonwealth v. Ruiz" on Justia Law

The Supreme Judicial Court affirmed Defendant’s conviction of murder in the first degree, as a joint venturer, holding that none of the arguments Defendant raised on appeal warranted reversal of his convictions.During trial, the Commonwealth proceeded on a theory of felony-murder, with armed home invasion and attempted armed robbery as the predicate felonies. The Supreme Judicial Court affirmed Defendant’s convictions and declined to exercise its authority to grant relief under Mass. Gen. Laws ch. 278, 33E, holding (1) the evidence was sufficient to support the convictions; (2) the trial judge did not abuse her discretion in allowing cell site location information evidence; (3) the judge did not err when she did not instruct the jury that they were allowed to reach factually inconsistent verdicts; and (4) this Court declines to abolish the common-law doctrine of felony-murder. View "Commonwealth v. Bin" on Justia Law

The Supreme Judicial Court reversed the trial court’s order suppressing statements that Defendant made during custodial interrogations and suppressing the results of the forensic testing of Defendant’s bloodstained clothing, holding (1) a remand was necessary to determine whether the suppression of Defendant’s statements was proper; and (2) the police lawfully seized Defendant’s clothing incident to arrest and did not need a separate warrant to test the clothing for the presence of human blood.Defendant was charged with murder in the first degree in connection with the beating death of a woman who had obtained a restraining order against him. The motion judge determined that Defendant was too intoxicated during custodial interviews to make a knowing, intelligent, and voluntary Miranda waiver. The Supreme Judicial Court disagreed, holding (1) a remand was necessary for the trial judge to make findings and credibility determinations regarding all pertinent evidence in light of this Court’s de novo assessment of the recording of Defendant’s second custodial interview; and (2) the order suppressing the results of the forensic testing of Defendant’s clothing must be reversed. View "Commonwealth v. Tremblay" on Justia Law

The Supreme Judicial Court vacated Defendant’s conviction of murder in the first degree on the theory of deliberate premeditation, holding that the judge erred by declining to require an explanation for the prosecutor’s preemptory challenge to a female African-American member of the venire and erred in declining to give Defendant’s requested jury instructions on self-defense and voluntary manslaughter.The shooting that led to the fatality in this case was precipitated by a drug turf war. At the close of the evidence Defendant requested that the jury be instructed on self-defense and voluntary manslaughter, but the request was denied. The Supreme Judicial Court reversed, holding (1) the trial judge abused her discretion by declining to require the prosecutor to provide and adequate and genuine race-neutral reason for Defendant’s peremptory challenge to the juror at issue; and (2) considered in the light most favorable to Defendant, the evidence warranted instructions on self-defense and voluntary manslaughter based on the theory of excessive use of force in self-defense. View "Commonwealth v. Ortega" on Justia Law

In this criminal matter, the Supreme Judicial Court held that maintaining pending charges against an incompetent defendant where the defendant will never regain competency and where maintaining the charges does not serve the compelling State interest of protecting the public violates the defendant’s substantive due process rights.In 1994, Defendant was charged with murder in the first degree but was deemed incompetent to stand trial. After unsuccessfully filing a series of motions to dismiss and for reconsideration, in 2016, Defendant sought relief pursuant to Mass. Gen. Stat. ch. 211, 3 arguing that he was permanently incompetent to stand trial and dismissal of the charges was required. At issue was Mass. Gen. Laws ch. 123, 16(f), which requires mandatory dismissal of charges at the time when the defendant would have been eligible for parole if he had been convicted and sentenced to the maximum statutory sentence. Defendant argued that the statute should be interpreted to apply to all crimes, regardless of parole eligibility. The Supreme Judicial Court agreed, holding that the statute satisfies due process requirements only insofar as it is understood to allow the dismissal of charges, in the interest of justice, where the defendant will never regain competency and does not pose a risk to public safety. View "Sharris v. Commonwealth" on Justia Law

The Supreme Judicial Court reversed the superior court judge’s denial of Defendant’s motion for resentencing, holding that Defendant, a juvenile convicted of armed home invasion, was sentenced to a mandatory minimum term exceeding that applicable to a juvenile convicted of murder without a hearing under Miller v. Alabama, 467 U.S. 460, 477-478 (2012), in violation of the requirements announced in Commonwealth v. Perez, 477 Mass. 677 (2017) (Perez I), and refined in Commonwealth v. Perez, 480 Mass. __ (2018) (Perez II), also decided today.Defendant was adjudicated a youthful offender on indictments charging armed home invasion and various related offenses and was sentenced to a mandatory minimum prison term of twenty years to twenty years and one day on the armed him invasion charge. Defendant later filed a motion for relief from unlawful restraint, which the juvenile court judge denied. The Supreme Judicial Court vacated the order denying Defendant’s motion and remanded to the juvenile court for resentencing, holding that Defendant’s sentence violated the proportionality requirement inherent in article 26 of the Massachusetts Declaration of Rights. View "Commonwealth v. Lutskov" on Justia Law

The Supreme Judicial Court held that “sexually dangerous person” (SDP) commitment extends only to those prisoners who are in Massachusetts custody serving a Massachusetts sentence at the time the Commonwealth files a commitment petition under Mass. Gen. Laws ch. 123A, 12(b).Defendant in this case was serving a Rhode Island sentence, albeit in a Massachusetts prison, when the Commonwealth filed the underlying petition in the superior court seeking his civil commitment as an SDP. The superior court granted Defendant’s motion to dismiss, finding that the Commonwealth lacked jurisdiction because Defendant was not serving a Massachusetts sentence and was under the jurisdiction of Rhode Island at the time the Commonwealth filed the petition. The Supreme Judicial Court affirmed after applying the required narrow construction of the SDP statute, Mass. Gen. Laws ch. 123A, 1, holding that the term “prisoner” does not include an individual in the custody of, and serving a sentence in, another state. View "Commonwealth v. Gardner" on Justia Law