Justia Massachusetts Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of murder in the second degree and carrying a firearm without a license. On appeal, Defendant argued, in part, that the trial judge erred in denying his motion for a mistrial on the ground that, during the jury’s deliberations, the jurors were exposed to extraneous materials and materials that had been excluded as evidence at trial. The Appeals Court rejected Defendant’s claims of error and affirmed the convictions. The Supreme Judicial Court affirmed, holding that the trial judge did not abuse her discretion in declining to declare a mistrial as a result of the jury’s exposure to the materials at issue during deliberations and in handling the circumstance as she did. View "Commonwealth v. Blanchard" on Justia Law

After a jury trial, Defendant was found guilty of murder in the first degree on a theory of deliberate premeditation. Defendant appealed from his convictions and from the trial court’s denial of his motion for a new trial, arguing, inter alia, that the motion judge erred in denying his pretrial motion to suppress the testimony of a key prosecution witness because the Commonwealth had obtained his testimony as a result of an illegal wiretap that was previously ordered suppressed. The Supreme Judicial Court affirmed and declined to exercise its authority under Mass. Gen. Laws ch. 278, 33E, holding (1) the motion judge did not err in determining that the witness’s testimony was sufficiently attenuated from the suppressed wiretap evidence to dissipate the taint of illegality; and (2) trial counsel provided constitutionally effective assistance. View "Commonwealth v. Long" on Justia Law

Defendants, Charles Mendez and Tacuma Massie, were convicted of murder in the first degree, armed robbery, and other offenses. Both defendants were charged on a theory of felony murder. Each defendant filed a timely notice of appeal. The Supreme Judicial Court affirmed Defendants’ convictions and declined to exercise its extraordinary power under Mass. Gen. Laws ch. 278, 33E, holding (1) the trial court did not err in denying Defendants’ motions to suppress evidence seized as a result of a warrantless stop that took place soon after the shooting; (2) the motion judge did not err in deciding to join for trial certain charges; (3) two aspects of the prosecutor’s closing argument challenged by Defendants were not error; (4) there was sufficient evidence to convict Massie of the armed robbery and felony murder; and (5) Defendants’ Moffett claims were unavailing. View "Commonwealth v. Mendez" on Justia Law

After a jury-waived trial, Defendant was found guilty of breaking and entering in the daytime with the intent to commit a felony and larceny of property over $250. Defendant’s fingerprint at the crime scene constituted the only identification evidence. On appeal, Defendant argued that the evidence was insufficient to support the convictions. The Appeals Court affirmed. The Supreme Judicial Court reversed, holding that the evidence was not sufficient to find, beyond a reasonable doubt, that Defendant left his fingerprint at the time of the break-in, and therefore, there was insufficient evidence to support the convictions. View "Commonwealth v. French" on Justia Law

A grand jury returned indictments against Defendant on various charges, including three counts of armed assault with intent to murder and murder in the second degree. Defendant moved to suppress the identification of him by an eyewitness, Brianna Johnson, and also moved to suppress Johnson’s identification of a firearm as the one used by Defendant in the commission of the crime. The motion judge denied the motion to suppress the identification of Defendant but allowed the motion to suppress the identification of the firearm. The Supreme Judicial Court affirmed, holding (1) under the circumstances of this case, the failure to detectives showing a photographic array to the eyewitness to use the protocol outlined in Commonwealth v. Silva-Santiago did not warrant suppression of Defendant’s identification of Defendant; (2) the use of a simultaneous rather than a sequential display of photographs in an array was not unnecessarily suggestive; and (3) the motion judge did not abuse his discretion in ruling the identification of the firearm as inadmissible under the common law of evidence due to suggestive police questioning and subsequent police confirmation. View "Commonwealth v. Thomas" on Justia Law

Defendant was charged with disorderly conduct. The charge arose from Defendant’s behavior as a patient in the psychiatric area of the emergency department at a Boston hospital. Defendant appealed, arguing that there was insufficient evidence to support his conviction. The Supreme Judicial Court reversed Defendant’s conviction, vacated the judgment, and remanded to the municipal court for entry of a judgment of dismissal, holding that the evidence was not sufficient to permit a reasonable jury to find beyond a reasonable doubt that Defendant consciously disregarded a “substantial and unjustifiable risk of public inconvenience, annoyance, or alarm.” View "Commonwealth v. Accime" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on the theory of deliberate premeditation. The Supreme Judicial Court affirmed Defendant’s convictions and declined to grant relief under Mass. Gen. Laws ch. 278, 33E, holding (1) the trial judge did not err by permitting the Commonwealth’s expert witness to opine that Defendant’s behavior was planned and goal-directed; (2) the trial judge did not erroneously permit the same expert to state the bases of her opinion on direct examination; and (3) the prosecutor did not make statements not supported by the evidence during closing arguments. View "Commonwealth v. Goddard" on Justia Law

Alexander Soto was a juvenile when he was indicted for murder in the first degree and related offenses. The superior court dismissed the non-murder indictments, concluding that the nonmurder charges must first be brought in the juvenile court by a complaint for delinquency or a youthful offender indictment prior to joinder with the murder indictments. The Supreme Judicial Court reversed the order allowing Soto’s motion to dismiss the non-murder indictments, holding that, when a juvenile is indicted for murder, non-murder offenses that are properly joined with the murder indictment must be brought in the superior court. View "Commonwealth v. Soto" on Justia Law

After a jury-waived trial, Defendant was convicted of one count of possession of child pornography with the intent to disseminate, one count of dissemination of child pornography, and three counts of possession of child pornography. Defendant appealed on three grounds. The Supreme Judicial Court affirmed, holding (1) the search warrant for the apartment in which Defendant was living was appropriately particularized; (2) the administrative subpoena that issued under Mass. Gen. Laws ch. 271, 17B for Internet service records was valid; and (3) the Commonwealth met the requirement of proving that Defendant had the lascivious intent necessary to support a conviction under Mass. Gen. Laws ch. 272, 29B. View "Commonwealth v. Molina" on Justia Law

After a jury trial, Defendant was convicted of possessing child pornography. Defendant appealed, arguing that the district court erred in denying his motion to suppress computer evidence obtained pursuant to a search warrant issued for the the place searched because the police needed more information to link Defendant to the place searched and the items seized. The Supreme Judicial Court affirmed, holding that there was a substantial basis from which to conclude that the evidence of downloading and sharing child pornography via the Internet was probably present at the place to be searched. View "Commonwealth v. Martinez" on Justia Law