Justia Massachusetts Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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After a jury trial, Defendant was convicted of murder in the first degree on the theory of deliberate premeditation. Defendant was sentenced to life in prison without parole. The Supreme Judicial Court affirmed Defendant’s conviction and the order denying his motion for a new trial and declined to grant relief under Mass. Gen. Laws ch. 278, 33E, holding (1) Defendant’s trial counsel did not render ineffective assistance by failing to request a jury instruction on voluntary manslaughter; (2) the trial court did not commit reversible error by declining Defendant’s request to give instructions on voluntary and involuntary manslaughter; and (3) the absence of these instructions did not constitute error requiring reversal of Defendant’s conviction and a new trial. View "Commonwealth v. Felix" on Justia Law

Posted in: Criminal Law
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Defendant was charged with operating while under the influence of intoxicating liquor, second offense, and a marked lanes violation. The charges stemmed from a single vehicle accident in which the vehicle Defendant was driving rolled over. Defendant filed a motion in limine to exclude from her medical records evidence of a blood alcohol test taken after she was transported to the hospital based on her right to confrontation under the Sixth Amendment. A district court judge allowed the motion. A single justice vacated the trial judge’s order allowing the motion in limine and ordered that the blood alcohol test evidence was admissible. The Supreme Judicial Court affirmed, holding that it was “eminently logical” that the blood alcohol test administered to Defendant was performed as a routine medical practice in the course of Defendant’s treatment following the accident. View "Commonwealth v. Ackerman" on Justia Law

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Defendant was convicted of murder in the first degree on the theories of deliberate premeditation and extreme atrocity or cruelty. The Supreme Judicial Court affirmed Defendant’s convictions and the trial court’s denial of his motion for a new trial and declined to grant extraordinary relief pursuant to Mass. Gen. Laws ch. 278, 33E, holding (1) Defendant received constitutionally effective assistance of counsel at trial; (2) Defendant was given a meaningful opportunity to present a complete defense; and (3) the trial judge did not deprive Defendant of his right to a fair trial by denying Defendant’s request to give a voluntary manslaughter instruction. View "Commonwealth v. Gulla" on Justia Law

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After a jury trial, Defendant was convicted of murder in the first degree on theories of deliberate premeditation and extreme atrocity or cruelty, arson of a dwelling house, and violating an abuse prevention order. The Supreme Judicial Court affirmed the convictions and declined to reduce the degree of guilt or to order a new trial, holding (1) the evidence was sufficient to support Defendant’s convictions of murder in the first degree and arson; (2) the testimony of two expert witnesses did not violate Defendant’s right to confrontation under the Sixth Amendment; (3) Defendant’s custodial statements to police were obtained with a valid Miranda waiver and were voluntary; and (4) the motion judge did not abuse his discretion in denying Defendant’s motion for a new trial without an evidentiary hearing. View "Commonwealth v. Sanchez" on Justia Law

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In 2007, Thomas Finneran, former Speaker of the House, pleaded guilty in federal district court to one count of obstruction of justice. The conviction stemmed from false testimony that Finneran had provided in relation to a federal court action challenging the 2001 redistricting act. Immediately after Finneran’s conviction, the State Retirement Board ceased payments of Finneran’s pension on the ground of his conviction under Mass. Gen. Laws ch. 32, 15(4). The hearing officer concluded that Finneran’s crime required the forfeiture of his pension under the statute because he had “been convicted of a criminal offense involving violation of the laws applicable to his office or position.” A municipal court judge reversed, concluding that there was no direct link between Finneran’s conviction and his position as a House Member and/or Speaker. The Supreme Judicial Court affirmed, holding that Finneran’s conviction of obstruction of justice was a “violation of the laws applicable to his office or position” and, therefore, required the statutory forfeiture of his pension. View "State Board of Retirement v. Finneran" on Justia Law

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After a joint jury trial, Defendants - John Squires and Steven Angier - were convicted of walking on a railroad track and possession of burglarious instruments. Defendants separately appealed, arguing, inter alia, that there was insufficient evidence to sustain the convictions of possession of burglarious implements. The Appeals Court affirmed. The Supreme Judicial Court reversed the judgments with respect to Defendants’ convictions of possession of burglarious instruments, holding that the Commonwealth failed to establish proof beyond a reasonable doubt of all of the elements of possession of burglarious instruments, and therefore, the evidence was insufficient to support the convictions. View "Commonwealth v. Squires" on Justia Law

Posted in: Criminal Law
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After a jury-waived trial, Defendant was convicted of wantonly or recklessly permitting another person to commit an assault and battery that resulted in bodily injury to her infant daughter. The injury was recklessly inflicted by Defendant’s boy friend after Defendant left her daughter in his sole care while she took a shower. The Appeals Court affirmed. The Supreme Judicial Court, holding that the evidence was not sufficient as a matter of law to find that Defendant’s conduct involved a high degree of likelihood that substantial harm would result to her daughter, and therefore, Defendant’s conviction of wantonly or recklessly permitting an assault and battery on the victim cannot be sustained. View "Commonwealth v. Dragotta" on Justia Law

Posted in: Criminal Law
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After a jury trial, Defendant was convicted of murder in the first degree on theories of deliberate premeditation and felony-murder. The Supreme Judicial Court affirmed the conviction and declined to grant relief under Mass. Gen. Laws ch. 278, 33E, holding (1) portions of the prosecutor’s closing argument were improper, but the impermissible statements, in the context of the entire argument, did not require a new trial; and (2) the trial judge did not abuse her discretion by allowing the prosecutor to introduce evidence of uncharged misconduct by Defendant for a nonpropensity purpose, and the probative value of the uncharged misconduct evidence outweighed the risk of unfair prejudice. View "Commonwealth v. Rutherford" on Justia Law

Posted in: Criminal Law
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After a jury trial, Defendants were each found guilty of murder in the first degree on a theory of deliberate premeditation and related offenses. The Supreme Judicial Court affirmed Defendants’ convictions and declined to reduce or set aside the verdicts under Mass. Gen. Laws ch. 278, 33E, holding (1) a certain witness’s grand jury testimony was properly admitted, and various statements in that testimony that Defendants claimed were independently inadmissible were also properly admitted; (2) certain portions of the prosecutor’s closing statement were not improper; (3) the jury instructions on immunized witness testimony were not error; (4) the trial judge did not err in denying Defendants’ motions to sever; and (5) the remaining issues raised by Defendants were without merit. View "Commonwealth v. DePina" on Justia Law

Posted in: Criminal Law
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Police officers recovered a loaded firearm from a motor vehicle after impounding and conducting an inventory search of the vehicle. Defendant was subsequently charged with carrying a firearm without a license and possession of a firearm or ammunition without a firearm identification card. Defendant filed a motion to suppress, arguing that the officers’ decision to impound and inventory the motor vehicle was not reasonable. A district court judge allowed the motion to suppress, concluding that impoundment was improper based on its findings that the vehicle was not in danger of damage or theft. The Supreme Judicial Court affirmed the order allowing the motion to suppress, holding that it was not reasonable for the police to impound the vehicle for the purpose of protecting it from theft or vandalism, and impoundment was not warranted to protect the public. View "Commonwealth v. Crowley-Chester" on Justia Law