Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed Defendant’s convictions for murder in the first degree on a theory of felony-murder and armed robbery and declined to grant extraordinary relief pursuant to Mass. Gen. Laws ch. 278, 33E. The Court held (1) the trial judge violated Defendant’s right to confront witnesses by allowing the jury to be exposed to certain hearsay, but the error was harmless beyond a reasonable doubt; (2) the trial judge erred by allowing a substitute expert witnesses to testify to a match between the defendant's DNA profile and one obtained from the victim's clothing, but the error did not result in a substantial likelihood of a miscarriage of justice; (3) Defendant’s trial counsel was not ineffective; and (4) government officials did not commit unconstitutional misconduct in the course of investigating and prosecuting Defendant. View "Commonwealth v. Seino" on Justia Law

The Supreme Judicial Court affirmed Defendant’s convictions for murder in the first degree on a theory of felony-murder and armed robbery and declined to grant extraordinary relief pursuant to Mass. Gen. Laws ch. 278, 33E. The Court held (1) the trial judge violated Defendant’s right to confront witnesses by allowing the jury to be exposed to certain hearsay, but the error was harmless beyond a reasonable doubt; (2) the trial judge erred by allowing a substitute expert witnesses to testify to a match between the defendant's DNA profile and one obtained from the victim's clothing, but the error did not result in a substantial likelihood of a miscarriage of justice; (3) Defendant’s trial counsel was not ineffective; and (4) government officials did not commit unconstitutional misconduct in the course of investigating and prosecuting Defendant. View "Commonwealth v. Seino" on Justia Law

The Supreme Judicial Court affirmed the adjudication of delinquency as to a juvenile offender under the age of sixteen, holding that, as applied in these circumstances where the juvenile maintained that he was involved in consensual experimentation with another child, enforcement of the statutory rape charge was constitutional.At the time of the alleged offenses, the juvenile was twelve years old and the victim was eight years old. A jury found the juvenile delinquent of statutory rape. On appeal, the juvenile argued that the imposition of criminal liability on a child for a strict liability offense was fundamentally unfair. The Supreme Judicial Court disagreed, holding that the juvenile’s arguments were unable to overcome the presumption that the Legislature acted reasonably and rationally in imposing strict liability for anyone who has sexual intercourse with a child under the age of sixteen. View "Commonwealth v. Wilbur W." on Justia Law

Because forty-five years had passed since Petitioner’s trial, it had not been definitively adjudicated that Petitioner’s loss of his direct appeal was due to any ineffective assistance of counsel, and Petitioner had not attempted to rectify the situation through a motion for a new trial, the order of the single justice allowing Petitioner’s petition to reinstate his direct appeal was reversed.In 1972, Petitioner was convicted of two counts of murder in the first degree and one count of robbery. Petitioner’s direct appeal was never perfected. In 1992, Petitioner filed a motion seeking an order directing the superior court clerk to transmit the record to the Supreme Judicial Court so that he could pursue his direct appeal. A single justice denied the motion. In 2014, Petitioner again filed a pro se motion for leave to file a late notice of appeal and a pro se petition to reinstate his direct appeal. In 2016, a single justice allowed Petitioner’s petition to reinstate his direct appeal and allowed his motion to file a late notice of appeal. The Supreme Judicial Court reversed for the reasons set forth above. View "White v. Commonwealth" on Justia Law

The Supreme Judicial Court reversed the judgment of a single justice of the county court denying the Commonwealth’s petition for relief pursuant to Mass. Gen. Laws ch. 211, 3 from an interlocutory ruling of the Boston Municipal Court Department, holding that the trial judge’s decision to deny the Commonwealth’s motion was clearly erroneous.Defendant was charged with several crimes stemming from an incident during which several individuals assaulted and robbery the victim. During the court of discovery, the Commonwealth provided Defendant with a copy of a DVD containing surveillance video. But as trial approached, the Commonwealth was unable to locate its own copy of the DVD. The day before trial, the Commonwealth moved for an order requiring Defendant to return to the Commonwealth a copy of the DVD for the Commonwealth’s use at trial. The trial judge denied the motion. The Commonwealth then filed this petition, which the single justice denied without a hearing. The Supreme Judicial Court reversed, holding that the Commonwealth’s use of Mass. Gen. Laws ch. 211, 3 was proper, and because the Commonwealth had no other remedy, the judge’s decision was clearly in error. View "Commonwealth v. Tahlil" on Justia Law

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