Justia Massachusetts Supreme Court Opinion Summaries

Defendant was indicted for multiple firearms offenses, among other offenses. Defendant moved to suppress evidence seized during the search of a motor vehicle he had been driving. A superior court judge allowed the motion, concluding that, at the time a police officer stopped and seized the vehicle, the officer lacked a reasonable, articulable suspicion that criminal activity was afoot. The Supreme Judicial Court reversed the motion judge’s order allowing the motion to suppress, holding (1) the investigatory stop was predicated on reasonable suspicion of criminal activity; and (2) the officer’s actions were “reasonably related in scope to the circumstances which justified the interference in the first place.” View "Commonwealth v. Edwards" on Justia Law

In Bridgeman v. District Attorney for the Suffolk District (Bridgeman I), the Supreme Judicial Court declined to accept a proposed “global remedy” of vacating the thousands of drug convictions affected by the misconduct of Annie Dookhan when she was employed as a chemist at the William A. Hinton State Laboratory Institute despite the claim that the time and expense of case-by-case adjudication had become untenable. Here, the district attorneys provided the single justice with lists identifying more than 20,000 potentially aggrieved defendants based on Dookhan’s misconduct. The single justice issued a reservation and report to the full court inviting it to reconsider its previous ruling. Rather than adopting Petitioners’ request for a global remedy, the Supreme Judicial Court adopted a new protocol for case-by-case adjudication. The adjudication will occur in three phases and be implemented by the single justice in the form of a declaratory judgment. View "Bridgeman v. District Attorney for the Suffolk District" on Justia Law

After a jury trial, Defendant was found guilty of murder in the first degree on theories of deliberate premeditation and extreme atrocity and cruelty. The Supreme Judicial Court affirmed the jury’s verdict, holding (1) the admission of testimony by a jailhouse informant did not violate Defendant’s confrontation rights; (2) a ballistics expert properly testified to a report prepared by an unavailable expert; (3) the admission of testimony of the Commonwealth’s wire expert created no substantial likelihood of a miscarriage of justice; (4) no reversible error occurred in the admission of two types of evidence resulting from searches of Defendant’s computer; and (5) the admission of transcript of the victim’s testimony from earlier proceedings involving both Defendant and the victim was not in error. View "Commonwealth v. Caruso" on Justia Law

Defendant, an inmate, was charged with falsely reporting a sexual assault to a deputy sheriff employed at the corrections facility. After a jury-waived trial, Defendant was convicted of making a false report of a crime to a police officer. Defendant appealed, arguing that a deputy sheriff is not a police officer within the meaning of Mass. Gen. Laws ch. 269, 13A, and therefore, the evidence was insufficient to sustain the conviction. The Supreme Judicial Court reversed, holding that a deputy sheriff is not a “police officer” within the meaning of the statute. View "Commonwealth v. Gernrich" on Justia Law

In 2012, the Boston Municipal Court issued a criminal complaint charging Defendant, who was mentally ill, with assault and battery by means of a dangerous weapon. Defendant has been in custody ever since, but each time the scheduled date approached, the trial was continued or else Defendant was found to be incompetent. Defendant unsuccessfully sought dismissal of the charge pursuant to Mass. Gen. Laws ch. 123, 16(f), under which a defendant who is found incompetent to stand trial is entitled to dismissal of the charge against him corresponding to one-half the maximum sentence the defendant could have received if convicted of the most serious crime with which he was charged. Defendant filed a petition for relief under Mass. Gen. Laws ch. 211, 3. The Supreme Judicial Court denied relief, holding (1) under section 16(f), the basis for the calculation of the date of dismissal is the maximum sentence provided for in the statute, regardless of the court in which the charges are pending; but (2) in this case, dismissal of the charge before the computed date may nevertheless be appropriate in the interest of justice. Remanded. View "Commonwealth v. Calvaire" on Justia Law

After a jury-waived trial, Defendant was convicted of various firearm charges. On appeal, Defendant challenged the denial of his motion to suppress the firearm, asserting that police officers lacked reasonable suspicion to stop him to investigate a report of shots fired at a vehicle. The Appeals Court affirmed. The Supreme Judicial court vacated the conviction and remanded for a new trial, holding that the motion judge erred in denying the motion to suppress because, assessing the totality of the circumstances leading to the stop of Defendant, the facts known to the police at the time of the seizure were not sufficient to establish reasonable suspicion that Defendant was connected to the alleged shooting at the vehicle. View "Commonwealth v. Meneus" on Justia Law

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