Justia Massachusetts Supreme Court Opinion Summaries

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

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