Justia Massachusetts Supreme Court Opinion Summaries

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

Defendant was acquitted on a charge of receipt of stolen property and then prosecuted for larceny of the same property. Defendant argues that the subsequent larceny complaint was properly dismissed on the ground of double jeopardy. The court concluded that the same elements test, firmly rooted in the court's history and case law, is the only appropriate test to apply in both single and successive prosecution scenarios. The court explained that, because larceny and receipt are not the same offense for double jeopardy purposes, dismissal of the larceny complaint on double jeopardy grounds is not warranted. Finally, the court concluded that the successive prosecutions do not violate the equitable principles of due process, collateral estoppel, and judicial estoppel. Accordingly, the court reversed the allowance of defendant's motion to dismiss on the ground of double jeopardy. View "Commonwealth v. Rodriguez" on Justia Law

After a jury trial, Appellant was convicted of two counts of unlawful possession of a loaded firearm and one count of possession of a firearm without a license. Appellant appealed, arguing that the Commonwealth failed to demonstrate that the police had reasonable suspicion to conduct an investigatory stop of his vehicle, and therefore, the trial court erred in denying his motion to suppress. The Court of Appeals agreed with Appellant and reversed the judgments of conviction, the verdicts, and the motion to suppress, holding that the police did not have reasonable suspicion to conduct the investigatory stop. View "Commonwealth v. Pinto" on Justia Law

Defendant was one of three occupants of a vehicle that was stopped for a traffic violation. When Defendant, the rear seat passenger, exited the vehicle based on an exit order, a police officer observed a handgun underneath his right thigh. At trial, the court ordered that evidence concerning the front seat passenger’s prior conviction of unlawful possession of a firearm was excluded for all purposes. Defense counsel violated this order and proceeded to elicit this testimony anyway. The judge declared a mistrial. Thereafter, Defendant moved to dismiss the charges on double jeopardy grounds, arguing that there had been no manifest necessity to declare a mistrial. A superior court judge denied the motion. Defendant then filed a petition pursuant to Mass. Gen. Laws ch. 211, 3. The single justice concluded that the trial judge had erred in determining that there was a manifest necessity to declare a mistrial. The Supreme Judicial Court remanded the matter to the county court for entry of an order denying Defendant’s petition, holding (1) there was no abuse of discretion in the judge’s decision to declare a mistrial on the ground of manifest necessity; and (2) the single justice applied a substituted judgment standard in finding otherwise. View "Commonwealth v. Bryan" on Justia Law