Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court interpreted one provision in the habitual criminal statute, Mass. Gen. Laws ch. 279, 25(a), which provides for an enhanced penalty where a defendant has two prior convictions resulting in prison sentences of three or more years, to require that the underlying convictions arise from separate incidents or episodes of criminal behavior. In so holding, the Court affirmed the superior court order dismissing the habitual offender portions of the indictments currently pending against Defendant, holding that the Commonwealth failed to provide the grand jury with sufficient evidence to support the habitual offender portions of the indictments. View "Commonwealth v. Garvey" on Justia Law

A jury found Earl T. Fulgiam and Michael T. Corbin guilty as joint venturers of murder in the first degree of Kevin Thomas, Jr. and Billie Marie Kee. The Supreme Judicial Court affirmed the convictions and declined to grant relief pursuant to Mass. Gen. Laws ch. 278, 33E, holding (1) the trial court did not err in admitting certain cellular telephone records; (2) the admission of fingerprint cards attributed to Defendants did not violate Defendants’ right to confront witnesses against them; (3) the trial judge did not err in admitting a fingerprint analyst’s testimony related to the fingerprint analysis; and (4) the prosecutor permissibly inferred that a “team” of men committed the murders. View "Commonwealth v. Fulgiam" on Justia Law

The Supreme Judicial Court affirmed Defendant’s conviction for murder in the first degree on theories of extreme atrocity or cruelty and deliberate premeditation, holding that there was no error in this case warranting reversal, nor was there any reason for the Court to exercise its authority under Mass. Gen. Laws ch. 278, 33E to reduce the verdict or order a new trial. Specifically, the Supreme Judicial Court held (1) the trial court did not err in denying Defendant’s motion to suppress a statement Defendant made to police; (2) the evidentiary rulings challenged by Defendant were unavailing; (3) there was no prejudicial error in the jury instructions; (4) the trial judge did not abuse his discretion in failing to dismiss several jurors for cause; (5) any potential prejudice to Defendant from the prosecutor’s closing argument was mitigated by a comprehensive limiting instruction; and (6) Defendant’s mandatory sentence of life in prison without the possibility of parole is constitutional. View "Commonwealth v. Colton" on Justia Law

Appellant appealed the denial of two Mass. Gen. Laws ch. 211, 3 petitions he filed related to ongoing trial court proceedings. The subject petitions were the fourth and fifth such petitions Appellant had filed in the county court seeking extraordinary relief from interlocutory trial courts rulings or otherwise related to ongoing trial court proceedings. The Supreme Judicial Court affirmed the judgments and placed Appellant on notice that any subsequent attempt to seek relief pursuant to Mass. Gen. Laws ch. 211, 3, where Appellant has an adequate alternative remedy or fails to comply with S.J.C. Rule 2:21, may result in restriction of future filings or other action by the Court. View "Afrasiabi v. Commonwealth" on Justia Law

Appellant filed a Mass. Gen. Laws ch. 211, 3 petition seeking interlocutory relief from an order of the superior court temporarily committing him to the Massachusetts Treatment Center pursuant to Mass. Gen. Laws ch. 123A, 12(e) pending a probable cause determination on the Commonwealth’s petition for Appellant’s civil commitment as a sexually dangerous person. A single justice denied relief on the ground that Appellant had an adequate remedy in the ordinary appellate process. The Supreme Judicial Court affirmed, holding that all of Appellant’s arguments as to the merits of his petition could be raised on appeal from an adverse final judgment in this matter. View "Schumacher v. Commonwealth" on Justia Law

Defendant was charged with offenses arising from alleged domestic violence. The Commonwealth and Defendant filed motions in limine regarding the admissibility of a record of a 911 call placed by the son of Defendant and the alleged victim. Defendant argued that the boy’s statements - including, “my dad just choked my mom” - were not excited utterances and that their admission would violate his right of confrontation right. The judge concluded that the statements were not excited utterances because the boy’s voice on the recording sounded “calm.” A single justice vacated the judge’s order excluding the recording. The Supreme Judicial Court affirmed, holding that the question is not whether the declarant shows “excitement,” but, rather, whether the declarant was acting spontaneously under the influence of the incident at the time the statements were made, and not reflexively. Remanded. View "Commonwealth v. Baldwin" on Justia Law

After a jury trial, Defendant was convicted of raping his nineteen-year-old stepdaughter, Sally. Defendant and Sally’s mother were married. The Appeals Court reversed, concluding that Sally was precluded from testifying about a private marital conversation between her mother and Defendant, the substance of which Sally’s mother had purportedly disclosed to her. Specifically, at trial, the mother denied that she told Sally that Defendant had confessed to the crime in a private conversation between the parties. To impeach the mother, however, Sally was permitted to testify to the contrary. The Supreme Judicial Court reversed Defendant’s conviction on other grounds, holding that the admission of this highly prejudicial evidence created a substantial risk of a miscarriage of justice. View "Commonwealth v. Garcia" on Justia Law

A complaint issued charging Defendant with misleading a police officer. The charge arose from Defendant’s act of picking up a small bag of what was believed to be heroin and swallowing it in full view of a police officer. A municipal court judge dismissed the count. The Appeals Court vacated the dismissal. The Supreme Judicial Court affirmed the order of the trial court judge allowing the motion to dismiss, holding (1) misleading conduct within the meaning of Mass. Gen. Laws ch. 268, 13B is conduct that is intended to create a false impression such that it was reasonably likely to send investigators in the wrong direction; and (2) in the instant case, Defendant’s actions were not misleading within the meaning of the statute. View "Commonwealth v. Tejeda" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on the theories of deliberate premeditation and extreme atrocity or cruelty, and armed home invasion. After filing a notice of appeal, Defendant filed a motion for a new trial arguing that his trial counsel was constitutionally ineffective for failing to investigate and present a defense of lack of criminal responsibility. Defendant also filed a second motion for a new trial. The trial court denied Defendant’s two motions for a new trial. The Supreme Judicial Court affirmed Defendant’s convictions and the orders denying the motions for a new trial and declined to reduce the verdict or grant a new trial, holding (1) the trial judge did not err in denying Defendant’s first motion for a new trial, as trial counsel’s decision to forgo further investigation of a lack of criminal responsibility defense based on mental illness was not error; and (2) Defendant’s remaining claims of error were either procedurally waived or without merit. View "Commonwealth v. Holland" on Justia Law

Defendant, a veteran of the United States Army, was arraigned in the district court on charges of operating a motor vehicle while under the influence of alcohol or drugs (OUI), second offense; possession of heroin; negligent operation of a motor vehicle; and leaving the scene of property damage. Defendant sought pretrial diversion under the VALOR Act. Defendant subsequently filed a motion pursuant to the pretrial diversion statute seeking dismissal of all charges should the pretrial diversion program prove successful. The prosecutor opposed the motion. Acknowledging that the case presented an unsettled question of law, the judge reported the following two questions to the Appeals Court. The Supreme Judicial Court allowed Defendant’s application for direct appellate review and held (1) under the pretrial diversion statute, as amended by the VALOR Act, a judge is authorized to dismiss or to continue criminal charges without a finding upon a defendant’s successful completion of an approved pretrial diversion program; and (2) the pretrial diversion statute, as amended by the VALOR Act, vests judges with discretion to either continue without a finding or to dismiss a charge of OUI in appropriate cases that involve charges of OUI, second or subsequent offense. View "Commonwealth v. Morgan" on Justia Law