Justia Massachusetts Supreme Court Opinion Summaries

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

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

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

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

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

Police made two warrantless entries into Defendant’s apartment after receiving reports that it smelled like drugs. Based on observations of drug activity, the policy obtained a warrant. Thereafter, Defendant was arrested and charged with drug offenses. The trial judge granted Defendant’s motions to suppress (1) the evidence seized during the execution of the search warrant, concluding that no emergency justified the warrantless entries, without which the Commonwealth could not establish he probable cause necessary for the subsequent warrant, and (2) statements Defendant made to police following his arrest, concluding that the statements were the fruit of Defendant’s unlawful arrest. The Supreme Judicial Court affirmed, holding (1) the warrantless entries were unlawful; and (2) the Commonwealth did not meet its burden of showing that Defendant’s statements were sufficiently attenuated from the Commonwealth’s unlawful conduct. View "Commonwealth v. Tuschall" on Justia Law

After a jury trial, Defendant was convicted of three counts of assault and battery and one count of kidnapping. The conviction arose out of an incident of domestic violence. The Supreme Judicial Court affirmed, holding (1) the trial judge did not abuse his broad discretion in finding an impermissible pattern at the point he rejected Defendant’s peremptory challenge to a certain female juror; (2) the trial judge did not err in admitting evidence of a prior incident of alleged domestic violence between Defendant and the victim; and (3) there was sufficient evidence to support Defendant’s kidnapping conviction. View "Commonwealth v. Oberle" on Justia Law

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