Justia Massachusetts Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of possession of cocaine with intent to distribute. The Appeals Court affirmed. Defendant appealed, arguing that the admission into evidence of expert testimony opining as to the typical physical characteristics of “crack” cocaine addicts was inadmissible “negative profiling” evidence. The Supreme Judicial Court agreed with Defendant and vacated the judgment, holding (1) the trial court erred in admitting the expert’s testimony concerning the physical characteristics of crack cocaine addictions; and (2) the error created a substantial risk of a miscarriage of justice. Remanded for further proceedings. View "Commonwealth v. Horne" on Justia Law

After a jury trial, Defendant was convicted of murder in the second degree and assault and battery by means of a dangerous weapon. Defendant appealed, arguing that, based on the evidence presented at trial and the prosecutor’s closing argument, the judge erred in denying his motion for a required finding of not guilty and denying his motion to reduce the verdict to a conviction of manslaughter. The Supreme Judicial Court held (1) there was sufficient evidence to convict Defendant of murder in the second degree; (2) the prosecutor’s closing argument was not improper; and (3) because the trial judge did not state his reasons for denying Defendant’s motion to reduce the verdict and because the trial judge has since become a member of the Supreme Judicial Court, the part of the case regarding the motion to reduce the verdict is transferred to the county court to review anew Defendant’s motion. View "Commonwealth v. Grassie" on Justia Law

Defendant was watching a feature in an “unsolved crime” series news broadcast with his girl friend’s mother when he told her he had been the shooter in the surveillance footage showing the suspect that was aired in the broadcast. During Defendant’s trial, the superior court judge allowed into evidence a redacted version of the news broadcast. Defendant was ultimately convicted of murder in the first degree on a theory of deliberate premeditation. Defendant’s principal argument on appeal was that the news broadcast should not have been admitted into evidence or, alternatively, that it should have been more heavily redacted. The Supreme Judicial Court affirmed the conviction, holding (1) the trial judge did not err in allowing admission of the news broadcast; and (2) there was no error requiring reversal in Defendant’s other challenges. View "Commonwealth v. Martinez" on Justia Law

Defendant was charged with murder in the first degree. Defendant filed a motion to suppress statements he made at two police stations, arguing that he did not knowingly and intelligently waive his Miranda rights and that the statements were not made voluntarily. Defendant then moved to impound a video recording and transcript of a police interview with Defendant that was the subject of the motion to suppress and that was subsequently suppressed. A superior court judge orally denied the motion to impound. A single justice of the Appeals Court denied Defendant’s request for interlocutory relief. A single justice of the Supreme Judicial Court vacated the denial of the motion to impound, concluding that the single justice committed an error of law and abused his discretion in affirming the judge’s denial of the motion to impound. The Supreme Judicial Court affirmed the motion judge's denial of the motion to impound, holding (1) the motion judge applied the correct legal standard in deciding Defendant’s motion to impound; and (2) the motion judge did not abuse his discretion in denying the motion to impound. View "Commonwealth v. Chism" on Justia Law

The school zone statute punishes individuals who commit certain enumerated drug offenses within 300 feet of a school or 100 feet of a public park or playground. Defendant was a passenger in a motor vehicle that was driven on a public roadway past a public park and stopped at a red light. When the light turned green, law enforcement officers stopped the vehicle, at which point the vehicle was no longer within 100 feet of the public park. The officers searched the vehicle and found drugs and a firearm. Defendant was arrested and charged with a number of offenses, including committing a drug offense within one hundred feet of a public park, in violation of Mass. Gen. Laws ch. 94C, 32J. Defendant moved to dismiss the park zone charge, arguing that the school zone statute is unconstitutional as applied to him. The judge allowed the motion. The Supreme Court affirmed, holding that application of Mass. Gen. Laws ch. 94C, 32J to Defendant, under the facts and circumstances of this case, would be overreaching. View "Commonwealth v. Peterson" on Justia Law

After a jury trial, Defendant was convicted of open and gross lewdness and lascivious behavior and resisting arrest. The Appeals Court affirmed. The Supreme Judicial Court (1) affirmed the judgment of conviction of resisting arrest; but (2) reversed the judgment of conviction of open and gross lewdness and lascivious behavior, holding that there was insufficient evidence that Defendant’s conduct caused any person to experience “shock” or “alarm,” as required by Mass. Gen. Laws ch. 272, 16. Because Defendant did not challenge the sufficiency of the evidence with respect to the first four elements of open and gross lewdness and lascivious behavior, the case was remanded for entry of a conviction of the lesser included offense of indecent exposure. View "Commonwealth v. Maguire" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on a theory of felony murder, armed home invasion, and armed assault with intent to rob. Defendant filed a motion for a new trial on the ground that the trial judge should have provided the jury with a felony murder merger instruction. The trial judge granted the motion as to the felony murder conviction but did not disturb Defendant’s remaining convictions. At Defendant’s retrial, a second jury found Defendant not guilty of the single charge of felony murder. In this appeal, Defendant argued, inter alia, that he cannot be guilty of his armed home invasion and armed assault with intent to rob convictions because the second jury acquitted him of felony murder predicated upon the same underlying felonies. The Supreme Judicial Court affirmed Defendant’s convictions, holding (1) the second trial cannot spare Defendant from the consequences of convictions properly decided by a different jury; and (2) Defendant’s claims of error in the first trial were unavailing. View "Commonwealth v. Resende" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on a theory of extreme atrocity or cruelty. The Supreme Judicial Court affirmed and declined to grant extraordinary relief pursuant to Mass. Gen. Laws ch. 278, 33E, holding (1) Defendant has not shown that the presence of police officers during the grand jury proceedings caused a substantial likelihood of a miscarriage of justice; (2) the trial judge did not err in denying Defendant’s motion for the appointment of a special prosecutor; (3) the trial judge did not commit prejudicial error in its evidentiary rulings challenged by Defendant; (4) statements made by the prosecutor during his opening statement and closing argument did not warrant reversal; and (5) the trial judge did not abuse his discretion in denying Defendant’s motion for a new trial. View "Commonwealth v. Holley" on Justia Law

In a four-count complaint, Defendant was charged with several criminal offenses. Defendant pleaded guilty as to counts one and four. The municipal court judge dismissed counts two and three for lack of probable cause. The Commonwealth appealed. The Appeals Court reversed the dismissal of these counts. The Supreme Judicial Court affirmed, holding that, while Defendant conceded that probable cause existed to support counts two and three, the complaint was also adequate to charge Defendant with each offense and to establish jurisdiction in the municipal court. View "Commonwealth v. Hardin" on Justia Law

In 2011, Defendant pleaded guilty to possession of a class B substance. Defendant was sentenced to a one-year term of probation and the probation supervision fees and the victim-witness assessment. The Commonwealth entered a nolle prosequi on the underlying complaint after a judge granted Defendant’s motion to withdraw his guilty plea on the ground that Annie Dookhan, the discredited analyst at the William A. Hinton State Laboratory Institute at the center of misconduct allegations, performed the analysis of the substances seized during Defendant’s arrest. Thereafter, Defendant filed a motion for return of property, including probation supervision fees and the victim-witness assessment. The judge denied the motion. The Supreme Judicial Court affirmed, holding that there is no statutory basis for a refund of victim-witness assessments or probation fees where a defendant’s conviction is vacated after the withdrawal of a guilty plea. View "Commonwealth v. Martin" on Justia Law