Justia Massachusetts Supreme Court Opinion Summaries

Articles Posted in Criminal Law
by
The Supreme Judicial Court affirmed the conviction of Defendant for murder in the first degree on a theory of deliberate premeditation and declined to grant extraordinary relief pursuant to Mass. Gen. Laws ch. 278, 33E. Specifically, the Supreme Judicial Court held (1) the presence of investigating police officers in the grand jury room during witness testimony in support of the indictments against Defendant did not result in structural error requiring the reversal of Defendant’s convictions; (2) Defendant did not receive ineffective assistance of counsel during trial, nor was there prosecutorial misconduct; and (3) the admission of statements Defendant made during an interview with police did not violate his Miranda rights. View "Commonwealth v. Woollam" on Justia Law

by
The Supreme Judicial Court affirmed Defendant’s conviction for murder in the first degree and aggravated rape and declined to exercise its extraordinary power under Mass. Gen. Laws ch. 278, 33E to reduce the verdict in this case arising from a reopened investigation into a previously unsolved murder. The court held (1) challenged statements made by the prosecutor during closing argument did not create a substantial likelihood of a miscarriage of justice; and (2) because there was no error in the prosecutor’s statements during closing argument, Defendant failed in his argument that trial counsel was ineffective for failing to object to the improper statements in the prosecutor’s closing. View "Commonwealth v. Diaz" on Justia Law

by
The Supreme Judicial Court affirmed the denial of Defendant’s motion to exclude the results of a breathalyzer test taken by the Alcotest 7110 MK III-C at his trial for operating a motor vehicle while under the influence of alcohol.In an earlier appeal, the Supreme Judicial Court remanded this case to the district court to conduct a hearing on the scientific reliability of the Alcotest. After a hearing, the district court concluded that the Alcotest was capable for producing scientifically reliable breath test results and denied Defendant’s motion to exclude this evidence. The Supreme Judicial Court affirmed, holding that the district judge did not abuse his discretion in finding that the Alcotest satisfies the Daubert-Lanigan standard for the admissibility of scientific evidence. View "Commonwealth v. Camblin" on Justia Law

by
The Supreme Judicial Court affirmed the decision of the Sex Offender Registry Board to deny Plaintiff’s petition to reopen his classification hearing where the petition, filed six years after the Board’s final decision, did not adequately explain the delay and did not allege prejudice.Plaintiff was classified by the Board as a level three sex offender. More than six years later, Plaintiff sought to reopen his classification hearing, arguing that the Board violated his procedural due process rights when it held the hearing without ensuring that Plaintiff’s waiver of counsel was knowing and voluntarily. The Board summarily denied the petition for rehearing as untimely. The Supreme Judicial Court affirmed without reaching Plaintiff’s due process claim, holding that, under the circumstances, the Board’s denial of Plaintiff’s petition to reopen his classification hearing was not an abuse of discretion. View "Doe, Sex offender Registry Board No. 209081 v. Sex Offender Registry Board" on Justia Law

by
The Supreme Judicial Court affirmed the judgment of a single justice of the court dismissing as moot Petitioner’s petition filed pursuant to Mass. Gen. Laws ch. 211, 3. Petitioner, an inmate, filed a complaint claiming that Respondents violated his civil rights by failing to provide him with a diabetic snack. A judge allowed Respondents’ motion to dismiss, and Petitioner filed a notice of appeal. Petitioner then filed this petition claiming that the trial court clerk’s office had not acted on his notice of appeal. The single justice dismissed the petition as moot because Petitioner’s notice of appeal had already been docketed in the trial court. The Supreme Judicial Court affirmed, holding that the single justice did not err in dismissing the Mass. Gen. Laws ch. 211, 3 petition as moot. View "Ewing v. Davenport-Mello" on Justia Law

by
The Supreme Judicial Court vacated the order denying the Commonwealth’s motion to dismiss the civil complaint filed by Plaintiff seeking compensation under the erroneous convictions statute, Mass. Gen. Laws ch. 258D. Plaintiff filed the complaint after the appeals court reversed his conviction for unlawful possession of a dangerous weapon. The superior court denied the Commonwealth’s motion to dismiss. The Supreme Judicial Court remanded the case to the superior court with directions to enter judgment for the Commonwealth, holding that Plaintiff’s conviction was not overturned on grounds tending to establish his innocence, thereby rendering him ineligible for compensation under the statute. View "Peterson v. Commonwealth" on Justia Law

by
The Supreme Judicial Court vacated the order denying the Commonwealth’s motion to dismiss the civil complaint filed by Plaintiff seeking compensation under the erroneous convictions statute, Mass. Gen. Laws ch. 258D. Plaintiff filed the complaint after the appeals court reversed his conviction for unlawful possession of a dangerous weapon. The superior court denied the Commonwealth’s motion to dismiss. The Supreme Judicial Court remanded the case to the superior court with directions to enter judgment for the Commonwealth, holding that Plaintiff’s conviction was not overturned on grounds tending to establish his innocence, thereby rendering him ineligible for compensation under the statute. View "Peterson v. Commonwealth" on Justia Law

by
The Supreme Judicial Court affirmed Defendant’s conviction for murder in the first degree on a theory of deliberate premeditation and declined to exercise its extraordinary power under Mass. Gen. Laws ch. 278, 33E. On appeal, Defendant argued that his defense counsel, the trial judge, and the prosecutor all committed error, requiring a new trial. The Supreme Judicial Court held (1) any error on the part of the defense counsel did not create a substantial likelihood of a miscarriage of justice; (2) the admission of certain prior bad act evidence was error, but there was no substantial likelihood of a miscarriage of justice; (3) there was no error in the prosecutor’s remarks during closing argument; and (4) there was no error in the jury instructions. View "Commonwealth v. Vazquez" on Justia Law

by
The Supreme Judicial Court affirmed Defendant’s conviction for murder in the first degree on a theory of deliberate premeditation and declined to exercise its extraordinary power under Mass. Gen. Laws ch. 278, 33E. On appeal, Defendant argued that his defense counsel, the trial judge, and the prosecutor all committed error, requiring a new trial. The Supreme Judicial Court held (1) any error on the part of the defense counsel did not create a substantial likelihood of a miscarriage of justice; (2) the admission of certain prior bad act evidence was error, but there was no substantial likelihood of a miscarriage of justice; (3) there was no error in the prosecutor’s remarks during closing argument; and (4) there was no error in the jury instructions. View "Commonwealth v. Vazquez" on Justia Law

by
The Supreme Judicial Court vacated and set aside Defendant’s conviction for murder in the first degree on the theory of felony-murder, with unarmed robbery as the predicate felony, and remanded the matter to the superior court for further proceedings, holding that Defendant’s trial counsel provided constitutionally ineffective assistance. The Supreme Judicial Court held (1) the evidence was sufficient to support Defendant’s conviction; but (2) Defendant was entitled to a new trial because his trial counsel was deficient for failing to have filed a motion to suppress the search of Defendant’s cellular telephone, and the improperly-admitted evidence likely influenced the jury’s verdict. View "Commonwealth v. Morin" on Justia Law