Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed the orders of the superior court on Appellant’s motions to vacate his conviction and dismiss the underlying charge, for a so-called “Cotto order” pursuant to Commonwealth v. Cotto, 471 Mass. 97 (2015), for postconviction discovery, and for a new trial.In his motions, Appellant argued that the Commonwealth had not fully investigated misconduct at the William A. Hinton State Laboratory Institute. The judge determined that some limited postconviction discovery was warranted and concluded that she could not fairly rule on Appellant’s motion for a new trial until that limited discovery was complete. The judge denied the remaining motions. The Supreme Judicial Court held that, on the basis of the record that was before her, the superior court judge’s rulings were correct. View "Commonwealth v. Escobar" on Justia Law

The Supreme Judicial Court affirmed Defendant’s conviction of possession with intent to distribute marijuana and reversed his conviction of unlawful cultivation of marijuana, holding that the jury instructions on unlawful cultivation were erroneous, and this error created a substantial risk of a miscarriage of justice. In addition, the evidence was insufficient to support a finding that Defendant, a medical marijuana patient, exceeded the home cultivation limit. The Court further held (1) there was sufficient probable cause for the search warrant, and Defendant’s motion to dismiss also was properly denied; (2) even if the jury instruction on possession with intent to distribute was in error, it did not create a substantial risk of a miscarriage of justice; and (3) the evidence was sufficient to support Defendant’s conviction of possession with intent to distribute beyond a reasonable doubt. View "Commonwealth v. Richardson" on Justia Law

The absolute prohibition against civilian possession of stun guns under Mass. Gen. Laws ch. 140, 131J violates the Second Amendment to the United States Constitution.Defendant was charged with possession of a stun gun, among other crimes. Defendant to dismissed that count of the complaint, arguing that section 131J’s criminal prohibition of the possession of stun guns by civilians violates the Second Amendment. The trial judge denied the motion. The Supreme Judicial Court vacated the district court’s order denying Defendant’s motion to dismiss and directed the judge to allow the motion, holding (1) stun guns are “arms” within the protection of the Second Amendment and therefore may be regulated but not absolutely banned; (2) consequently, the absolute prohibition in section 131J that bars all civilians from possessing or carrying stun guns, even in their home, violates the Second Amendment; and (3) section 131J in its current form is facially invalid. View "Ramirez v. Commonwealth" on Justia Law

Mass. Gen. Laws ch. 119, 72A permits a juvenile court judge to transfer lesser included offenses when supported by probable cause even where lesser included offenses are not expressly charged.In 2014, juvenile delinquency complaints were issued against Defendant for the crime of rape of a child with force for incidents that occurred when Defendant was sixteen years old. Because Defendant was not “apprehended” until after his nineteenth birthday, the juvenile court judge was faced with discharging Defendant or transferring the charges to adult court. The judge dismissed the offenses charged for lack of probable cause but transferred the lesser included offenses of statutory rape. Defendant filed a petition for relief pursuant to Mass. Gen. Laws ch. 211, 3. The Supreme Judicial Court held that because the judge in this case did not inform Defendant of her probable cause rulings on the offenses charged or the lesser included offenses until her decision on the transfer itself, Defendant was not given a meaningful opportunity to present evidence and argument why discharge rather than transfer of the statutory rape charges was consistent with protection of the public. Therefore, Defendant was entitled to reopen the transfer hearing in order to present such evidence and argument. View "J.H. v. Commonwealth" on Justia Law

The Supreme Court affirmed the decision of the resentencing judge, holding that Defendant’s resentencing scheme was neither illegal nor unconstitutional.Defendant was convicted of stalking, harassment, two counts of restraining order violations, and two counts of perjury. While Defendant was serving his stalking sentence, that conviction was vacated for insufficiency of the evidence. Defendant was then resentenced on the remaining convictions. On appeal, Defendant argued that the structure of his resentencing scheme was illegal. The Appeals Court dismissed Defendant’s case as moot. The Supreme Court granted further appellate review and affirmed the decision of the resentencing judge, holding that Defendant’s resentencing scheme was both legal and constitutional. View "Commonwealth v. Walters" on Justia Law

At issue was the appropriate standards and procedures for requests by the Commonwealth and parties to a care and protection proceeding in the juvenile court for the release of impounded records of the proceeding.Here, Mother and Father were the subjects of a care and protection proceeding, the records from which were impounded, and the defendants in criminal child abuse cases. Father and the Commonwealth sought access to the impounded records in conjunction with the upcoming criminal trials. The Supreme Judicial Court held (1) where a party to a care and protection proceeding or the Commonwealth seeks access to impounded records of the proceeding, the requestor must demonstrate that the records should be released under the good cause standard of rule 7 of the Uniform Rules on Impoundment Procedure; and (2) if the good cause standard is met, records may be disclosed for limited, confidential review and use, but the discoverability of the records does not also make them admissible at a subsequent criminal proceeding. View "Care and Protection of M.C." on Justia Law

The phrase “anything of value” as it appears in Mass. Gen. Laws ch. 266, 37E(b), the statute criminalizing identity fraud, does not include avoiding criminal prosecution.Defendant pleaded guilty to identity fraud in connection with providing a false name to a police officer during a traffic stop. Defendant filed a motion to withdraw her guilty plea, arguing that there were insufficient facts to establish that she attempted to receive, or received, anything of value within the meaning of section 37E(b). The judge denied the motion. The Supreme Judicial Court reversed, holding that the Commonwealth failed to establish that Defendant attempted to obtain something of value pursuant to the statute because the evasion of criminal prosecution is not something of value within the meaning of the statute. View "Commonwealth v. Escobar" on Justia Law

The phrase “anything of value” as it appears in Mass. Gen. Laws ch. 266, 37E(b), the statute criminalizing identity fraud, does not include avoiding criminal prosecution.Defendant pleaded guilty to identity fraud in connection with providing a false name to a police officer during a traffic stop. Defendant filed a motion to withdraw her guilty plea, arguing that there were insufficient facts to establish that she attempted to receive, or received, anything of value within the meaning of section 37E(b). The judge denied the motion. The Supreme Judicial Court reversed, holding that the Commonwealth failed to establish that Defendant attempted to obtain something of value pursuant to the statute because the evasion of criminal prosecution is not something of value within the meaning of the statute. View "Commonwealth v. Escobar" on Justia Law

At issue was whether the sentencing judge erred in resentencing Defendant, who was convicted of certain sex offenses, to include, approximately ten months after he was originally sentenced, the condition that he be subject to global positioning system (GPS) monitoring as a condition of his probation.The Supreme Judicial Court held that because Defendant did not receive actual notice from the sentencing judge at the time of sentencing that GPS monitoring was included as a special condition of Defendant's probation, and because resentencing occurred after the statutory sixty-day period in which an illegal sentence may be corrected, the belated imposition of GPS monitoring must be vacated. View "Commonwealth v. Grundman" on Justia Law

In this case where the Commonwealth filed a petition seeking to commit Petitioner as a sexually dangerous person in 2010 but, after three mistrials, Petitioner remained confined without a finding that he was sexually dangerous, the Supreme Judicial Court held (1) Mass. Gen. Laws ch. 123A, the statute governing civil commitment of sexually dangerous persons (SDP), permitted a fourth trial under the circumstances of this case; but (2) Petitioner’s nearly seven-year confinement without a finding of sexual dangerousness violated his substantive due process rights under the Fifth and Fourteenth Amendments of the United States Constitution and the Massachusetts Declaration of Rights. Accordingly, Petitioner must be given the opportunity to seek supervised release prior to his fourth trial. View "Commonwealth v. G.F." on Justia Law