Justia Massachusetts Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of assault and battery on a family or household member in violation of Mass. Gen. Laws ch. 266, 13M(a). On appellate review, Defendant argued that the evidence was insufficient to support a conviction under the statute because he was not involved in a “substantive dating relationship” with the person he was charged with assaulting. The Supreme Judicial Court affirmed, holding that the evidence warranted a finding beyond a reasonable doubt that Defendant was involved in a “substantive dating relationship” with the person he was charged with assaulting, in violation of Mass. Gen. Laws ch. 265, 13M(c). View "Commonwealth v. Dustin" on Justia Law

Petitioner was charged in three different indictments with three criminal offenses. Each of the cases were pending in the superior court where the court imposed a unified bail. The total bail in the three cases was $3,000. After Petitioner defaulted, the court revoked the previous order of bail and set a new unified bail in the amount of $13,000. The court then held a bail forfeiture hearing in which the court allowed forfeiture in one case. Petitioner forfeited $500 in that case. After the bail forfeiture, Petitioner filed a petition pursuant to Mass. Gen. Laws ch. 211, 3 asking the county court to vacate the bail orders, release him, order his $500 to be returned, and dismiss all three superior court cases. The single justice denied relief with the exception of holding that once the default had been removed, the $500 in bail should not have been forfeited. The Supreme Judicial Court affirmed, holding that the single justice did not err in denying relief pursuant to Mass. Gen. Laws ch. 211, 3 and properly held that Petitioner may seek return of the forfeited bail in the superior court. View "Tavares v. Commonwealth" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on theories of extreme atrocity or cruelty and felony-murder. Defendant was also convicted of nine other charges, including home invasion while armed with a dangerous weapon. The Supreme Judicial Court (1) affirmed the conviction of murder in the first degree and declined to exercise its power under Mass. Gen. Laws ch. 278, 33E to reduce the degree of guilt or to order a new trial; but (2) reversed Defendant’s conviction with respect to the charge of home invasion, holding that the evidence was insufficient to support the conviction. View "Commonwealth v. Bois" on Justia Law

In 2002, Defendant pleaded guilty to indecent assault and battery. In 2013, Defendant filed a motion to withdraw his guilty plea or for a new trial, arguing that his plea counsel was constitutionally ineffective by advising Defendant that he would need to “register” if he pleaded guilty to a sex offense without explaining the consequences of sex offender registration. The motion judge denied the motion, concluding that Defendant failed to establish that plea counsel was constitutionally ineffective. The Supreme Judicial Court affirmed, holding that plea counsel was not constitutionally ineffective in giving this advice in 2002, and the question of whether such advice would be constitutionally ineffective based on the current statutory scheme for sex offender registration is best left for another day. View "Commonwealth v. Sylvester" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on the theories of deliberate premeditation and extreme atrocity or cruelty and of home invasion. Defendant appealed, arguing, inter alia, that the evidence was insufficient as a matter of law to permit a rational jury to find beyond a reasonable doubt that he was criminal responsible at the time of the killing. The Supreme Judicial Court affirmed and declined to exercise its authority to order a new trial or to reduce the verdict of murder in the first degree, holding (1) the evidence was sufficient to permit a finding of criminal responsibility; (2) trial counsel did not provide ineffective assistance; (3) any impropriety in statements by the two prosecutors in their opening statement and closing argument was not prejudicial; and (4) the trial judge did not err in giving an instruction on the consequences of a verdict of not guilty by reason of lack of criminal responsibility. View "Commonwealth v. Griffin" on Justia Law

After a jury-waived trial, Defendant was found guilty of knowingly causing damage to another automobile in a private driveway and leaving without identifying himself to the owner in violation of Mass. Gen. Laws ch. 90, 24(2)(a). The Appeals Court affirmed. Defendant appealed, arguing that the prohibition against leaving the scene without providing identification after causing property damage includes as an element of the crime that the accident causing the damage occurred on a public way. The Supreme Judicial Court affirmed, holding that the plain language of the portion of Mass. Gen. Laws ch. 90, 24(2)(a), under which Defendant was convicted, does not contain a public way element. View "Commonwealth v. LeBlanc" on Justia Law

After a trial, Defendant was found guilty of two counts of assault and battery on a public employee, and one count each of assault and battery by means of a dangerous weapon, assault by means of a dangerous weapon, and resisting arrest. Defendant appealed, arguing that the trial judge erred in denying his motion for required findings of not guilty by reason of lack of criminal responsibility. Specifically, Defendant argued that the trial judge must have relied on a “presumption of sanity” because the evidence did not support a finding of criminal responsibility beyond a reasonable doubt. The Supreme Court affirmed, holding (1) although the Commonwealth may not rely on the so-called “presumption of sanity” to establish criminal responsibility, the Commonwealth may rely on the circumstances of the offense to prove the defendant’s criminal responsibility; and (2) the evidence in this case was sufficient to allow a reasonable finder of fact to find that Defendant was criminally responsible at the time of the offenses. View "Commonwealth v. Lawson" on Justia Law

After a jury trial, Defendant was convicted on two indictments charging violations of Mass. Gen. Laws ch. 268, 13B, the witness intimidation statute, which prohibits “willfully…mislead[ing]…[a] police officer.” Defendant's convictions arose from his conduct at two separate interviews with police during their investigation of a fight at a party Defendant hosted. Defendant appealed, arguing that the jury was incorrectly instructed regarding the elements of section 13B and that his motions for required findings of not guilty should have been allowed. The Supreme Judicial Court vacated the judgments of conviction, holding (1) the jury instruction regarding the “misleading” element of section 13B was incorrect; and (2) if the jury had been properly instructed, the evidence would have been sufficient to allow the jury to find Defendant guilty of violating section 13B at the first interview but not at the second interview. Remanded for entry of a required finding of not guilty with respect to the second indictment and for further proceedings consistent with this opinion. View "Commonwealth v. Paquette" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree and related offenses. The Supreme Judicial Court affirmed Defendant's convictions and declined to grant relief pursuant to Mass. Gen. Laws ch. 278, 33E, holding that the trial judge did not err by (1) denying Defendant’s motion for a required finding of not guilty; (2) admitting into evidence certain items that were seized from an apartment building owned by Defendant's parents; (3) permitting jurors to ask questions of the witnesses; (4) admitting or excluding certain testimonial evidence offered by various witnesses; and (5) denying Defendant’s request for a jury instruction on transferred intent. View "Commonwealth v. Gomes" on Justia Law

Plaintiff, a Massachusetts prison inmate, brought civil rights action claiming that Defendants violated his constitutional right to due process by holding him in a special management unit (SMU) - or solitary confinement - for ten months without a hearing while waiting to reclassify or transfer him. The Supreme Judicial Court held that segregated confinement on awaiting action status for longer than ninety days gives rise to a liberty interest entitling an inmate to notice and a hearing. On remand, the superior court entered declaratory judgment in favor of Plaintiff and awarded him attorney’s fees and costs. Defendants appealed, arguing that Plaintiff was not a prevailing party under 42 U.S.C. § 1988(b) because he had been discharged from SMU detention long before he won any relief, and therefore, the declaratory judgment was moot and did not directly benefit him or materially alter his relationship with Defendants. The Supreme Judicial Court affirmed, holding (1) Plaintiff did qualify as a prevailing party in the circumstances of this case; and (2) the award of fees to Plaintiff was reasonable. View "LaChance v. Commissioner of Correction" on Justia Law