Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed the judgment of the district court convicting Defendant of assault and battery and witness intimidation and imposing a sentence of a one-year commitment to a house of correction, suspended for two years, probation, and restitution. On appeal, Defendant argued in part that the district court lacked jurisdiction over the witness intimidation prosecution because the “witness” at issue was not a “witness” but a “potential witness” at the time of the assault. The Court held (1) the district court properly exercised jurisdiction over the prosecution of Defendant for witness intimidation because “witness” in the jurisdictional statute includes “a witness or potential witness at any stage of a criminal investigation, grand jury proceeding, trial or other criminal proceeding of any type,” as protected by Mass. Gen. Laws ch. 268, 13B(1)(c)(i); and (2) the district court did not prejudicially err in denying Defendant’s motion for a new trial, revocation of bail, and order of payment of restitution. View "Commonwealth v. Brown" on Justia Law

The dismissal of the criminal charge pending against Respondent, an incompetent defendant, did not require his release from commitment to Bridgewater State Hospital, where the charge was dismissed after the period of commitment had expired, and a petition to extend the commitment had yet to be decided.After the criminal charge against Respondent was dismissed, Bridgewater moved to file an amended petition to modify its pending Mass. Gen. Laws ch. 123, 16(c) petition to a petition for civil commitment pursuant to Mass. Gen. Laws ch. 123, 7 and 8. The district court concluded that Bridgewater had no authority to hold Respondent pursuant to Mass. Gen. Laws ch. 123, 16(c), denied Bridgewater’s petition to amend, and ordered Respondent discharged. The Supreme Judicial Court reversed, holding (1) the dismissal of the criminal charges did not require Respondent’s immediate release from commitment, and Bridgewater retained the statutory authority to hold Respondent while the Mass. Gen. Laws ch. 123, 16(c) petition was pending; and (2) the district court abused its discretion in denying Bridgewater’s request to amend its pending petition for an extension under Mass. Gen. Laws ch. 123, 16(c) to a petition for civil commitment under Mass. Gen. Laws ch. 123, 7 and 8. View "In re E.C." on Justia Law

The Supreme Judicial Court affirmed Defendant’s two convictions of murder in the first degree, holding that none of Defendant’s allegations of error warranted reversal. Specifically, the Court held (1) the pretrial motion judge did not err in denying Defendant’s motion to suppress statements he made to Canadian law enforcement officers; (2) the trial judge did not commit reversible error in ordering the pretrial disclosure of Defendant’s mental health expert’s report, which the prosecution had in its possession during its subsequent cross-examination of Defendant; (3) the evidence at trial did not demonstrate Defendant’s lack of criminal responsibility for the murders; (4) defense counsel did not provide ineffective assistance; and (5) State police investigators did not deny Defendant his right to a complete defense when they failed to collect certain evidence relevant to Defendant’s intoxication at the time of the crimes. View "Commonwealth v. Wright" on Justia Law

The Supreme Judicial Court affirmed Defendant’s conviction for murder in the first degree on the theory of deliberate premeditation and declined to allow relief under Mass. Gen. Laws ch. 278, 33E. The Court held (1) the trial judge properly denied Defendant’s motion to instruct the jury on the lesser included offense of voluntary manslaughter based on sudden combat; (2) the judge’s reasonable provocation instruction was not erroneous; (3) there was no error in the judge’s instructions as to lesser included offenses; (4) the trial judge did not err in dismissing a nondeliberating juror toward the end of the trial; and (5) an error in a limiting instruction given after the judge allowed the Commonwealth to introduce prior bad act evidence was harmless. View "Commonwealth v. Howard" on Justia Law

The Supreme Judicial Court affirmed the judgment of a single justice of the court, pursuant to Mass. Gen. Laws ch. 211, 3, denying Appellant relief from prison sentences that Appellant claimed were illegal, holding that Appellant failed to meet his burden of demonstrating the absence of other routes by which he may adequately seek relief and also failed to create a record to substantiate his allegations. Specifically, Appellant had other means by which to seek review of his claim that his sentence was illegal and could have raised his ineffective assistance of counsel claim in a postconviction motion and an appeal from any adverse ruling. Appellant also failed to provide a record sufficient to evaluate his claims. View "Sabree v. Commonwealth" on Justia Law

While an appellate court generally may remand a case for resentencing while affirming the underlying conviction, it was nevertheless improper to do so under the particular circumstances of this case.Defendant pleaded guilty to criminal offenses in 2000, and the charges were placed on file at that time. In 2014, a judge brought the filed charges forward and sentenced Defendant on them. The Appeals Court remanded the matter to give the sentencing judge an opportunity to explain the basis for the sentences he imposed. The Appeals Court then affirmed the convictions on the filed charges but vacated the sentences and remanded for resentencing due to doubts it had concerning their propriety. The Supreme Judicial Court held that the proper disposition of this case was simply to affirm the district court’s judgments without remand for resentencing because, once the convictions were affirmed, no purpose could be served by remanding the matter for resentencing because, while the case was pending in the Appeals Court, Defendant finished serving his sentences, rendering moot any error. View "Commonwealth v. Padua" on Justia Law

While an appellate court generally may remand a case for resentencing while affirming the underlying conviction, it was nevertheless improper to do so under the particular circumstances of this case.Defendant pleaded guilty to criminal offenses in 2000, and the charges were placed on file at that time. In 2014, a judge brought the filed charges forward and sentenced Defendant on them. The Appeals Court remanded the matter to give the sentencing judge an opportunity to explain the basis for the sentences he imposed. The Appeals Court then affirmed the convictions on the filed charges but vacated the sentences and remanded for resentencing due to doubts it had concerning their propriety. The Supreme Judicial Court held that the proper disposition of this case was simply to affirm the district court’s judgments without remand for resentencing because, once the convictions were affirmed, no purpose could be served by remanding the matter for resentencing because, while the case was pending in the Appeals Court, Defendant finished serving his sentences, rendering moot any error. View "Commonwealth v. Padua" on Justia Law

The police in this case had the authority to stop and perform a Terry-type search of a motor vehicle after an anonymous 911 caller reported that the driver of the vehicle threatened the caller, a fellow motorist, with a gun.Defendant, the driver of the vehicle at issue, was convicted of assault with a dangerous weapon. On appeal, Defendant argued that the police lacked probable cause to stop his vehicle, and therefore, the trial court should have suppressed the pellet gun found in his vehicle. The Appeals Court affirmed. The Supreme Court affirmed, holding (1) the information possessed by the police gave them reasonable, articulable suspicion to stop and perform a protective sweep of Defendant’s vehicle; (2) given the safety concerns of the police, reasonable suspicion was all that was required; and (3) therefore, the motion judge properly denied the motion to suppress. View "Commonwealth v. Manha" on Justia Law

The police in this case had the authority to stop and perform a Terry-type search of a motor vehicle after an anonymous 911 caller reported that the driver of the vehicle threatened the caller, a fellow motorist, with a gun.Defendant, the driver of the vehicle at issue, was convicted of assault with a dangerous weapon. On appeal, Defendant argued that the police lacked probable cause to stop his vehicle, and therefore, the trial court should have suppressed the pellet gun found in his vehicle. The Appeals Court affirmed. The Supreme Court affirmed, holding (1) the information possessed by the police gave them reasonable, articulable suspicion to stop and perform a protective sweep of Defendant’s vehicle; (2) given the safety concerns of the police, reasonable suspicion was all that was required; and (3) therefore, the motion judge properly denied the motion to suppress. View "Commonwealth v. Manha" on Justia Law

The Supreme Judicial Court affirmed Defendant’s conviction for murder in the first degree on theories of deliberate premeditation and extreme atrocity or cruelty, holding that the judge who conducted Defendant’s third competency hearing did not err in finding him competent to stand trial notwithstanding testimony from both prosecution and defense experts that he was not competent.Defendant argued both prior to and during trial that he was not competent to stand trial due to an organic brain injury and a diagnosis of pervasive developmental disorder. Competency hearings were held before five different judges, and Defendant was found competent to stand trial at the first, third, fourth, and fifth hearings. The Supreme Judicial Court affirmed, holding (1) the judge who conducted the third competency hearing used the correct standard procedure to determine competency, appropriately placed the burden on the Commonwealth to prove competency by a preponderance of the evidence, and properly explained the reasons for his decision, and thus, there was no error in his determination of competency; and (2) a mandatory sentence of life in prison without the possibility of parole, imposed on a developmentally disabled individual, does not constitute cruel and unusual punishment. View "Commonwealth v. Jones" on Justia Law