Justia Massachusetts Supreme Court Opinion Summaries

Plaintiffs in this putative class action were inmates serving criminal sentences in various Massachusetts prison facilities who had, for varying lengths of time, been placed in a special management unit (SMU) in nondisciplinary administrative segregation. Plaintiffs brought this action alleging that their placements in the SMUs violated their constitutional rights to due process, as well as regulations of the Department of Correction. Plaintiffs sought to represent a class of similarly situated prisoners confined in SMUs. A judge denied Plaintiffs’ motion for class certification and, relying on the Supreme Judicial Court’s decision in LaChance v. Commissioner of Correction, dismissed Plaintiffs’ complaint. The Appeals Court dismissed Plaintiffs’ appeal as moot, as, by then, no named plaintiffs remained in SMUs. The Supreme Judicial Court reversed, holding (1) in light of the class action allegations in Plaintiffs’ complaint, the appeal was not moot; and (2) LaChance did not resolve the merits of all of Plaintiffs’ claims. Remanded. View "Cantell v. Commissioner of Correction" on Justia Law

After a jury trial, Defendant was convicted of one count of rape of a child. The underlying indictment alleged that Defendant raped his daughter on diverse dates between 1979 and 1981. Defendant appealed, raising statute of limitations claims. The Supreme Judicial Court vacated Defendant’s conviction, holding (1) the Commonwealth presented sufficient evidence from which the jury could determine that the indictment was timely returned, but the jury instruction concerning how to make this determination was incorrect, which resulted in a substantial risk of a miscarriage of justice; (2) the required independent corroboration of any incidents of rape that occurred more than twenty-seven years before the indictment was returned must relate to the specific criminal act or acts of which a defendant is accused, and evidence of uncharged misconduct does not suffice; and (3) the Commonwealth’s corroborative evidence consisting only of evidence of uncharged misconduct was insufficient as a matter of law. Remanded for a new trial. View "Commonwealth v. White" on Justia Law

Defendant was convicted as a joint venturer of murder in the first degree, armed robbery, and assault and battery by means of a dangerous weapon. The Supreme Judicial Court affirmed the convictions and discerned to reason to exercise its authority to grant extraordinary relief, holding (1) the trial court did not err in denying Defendant’s motions for required findings of not guilty, as the evidence was sufficient to support the convictions; (2) the trial court did not err in denying Defendant’s motion to dismiss on speedy trial grounds, as Defendant acquiesced to an additional period of delay; and (3) certain evidence, including Defendant’s oral statements to police, was properly admitted at trial. View "Commonwealth v. Williams" on Justia Law

After a jury trial, Defendant was found guilty of possession with intent to distribute heroin and possession with intent to distribute cocaine. Defendant pleaded guilty to the subsequent offense portion of each of these charges. After a hearing, the trial judge stated that she would depart downward from the mandatory minimum sentence provisions of the two subsequent offense statutes. The Commonwealth filed a petition for relief pursuant to Mass. Gen. Laws ch. 211, 3. The Supreme Court allowed the Commonwealth’s petition for relief and vacated Defendant’s sentences, holding that because the Legislature has not yet enacted into law sentencing guidelines recommended by the Massachusetts Sentencing Commission, Mass. Gen. Laws ch. 211E, 3(e) does not authorize a sentencing judge to depart from the mandatory minimum terms specified by statute for subsequent drug offenses. View "Commonwealth v. Laltaprasad" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree and assault and battery with a dangerous weapon. The Supreme Judicial Court reversed the convictions and remanded the case for a new trial due to errors in Defendant’s first trial. On remand, Defendant was convicted of murder in the first degree by extreme atrocity or cruelty and assault and battery by means of a dangerous weapon. Defendant was sentenced to life in prison without the possibility of parole on the murder conviction. The Supreme Judicial Court affirmed on appeal, holding (1) the Commonwealth made improper statements during closing arguments, but this error did not warrant a new trial or other relief; (2) Defendant’s remaining allegations of error were unavailing; and (3) the Court discerns no basis to grant relief pursuant to Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Durand" on Justia Law

Prior to his scheduled release, the Commonwealth filed a petition to commit James Green as a sexually dangerous predator (SDP). Green was found sexually dangerous after a jury trial. Two months later, Green filed a petition for discharge pursuant to Mass. Gen. Laws ch. 123A, 9. After a trial, the jury returned their verdict that Green was not an SDP. The Commonwealth filed a motion for a new trial, challenging the trial judge’s instruction that in order to find Green sexually dangerous the jury must credit the expert opinion testimony of the qualified examiner. The trial court denied the motion. The Supreme Judicial Court affirmed, holding (1) a finding of sexual dangerousness must be based at least in part on credible qualified examiner opinion testimony; and (2) therefore, there was no error in the judge’s instruction that the jury must credit the qualified examiner’s opinion to reach a finding of sexual dangerousness. View "In re Green" on Justia Law

Defendant was stopped for failing to stop at a stop sign. The officer concluded that Defendant was using the vehicle without authority and decided to impound the vehicle. During an inventory search in preparation for impoundment, the officer seized a handgun and box of ammunition from the vehicle. Defendant was charged with unlawful possession of a firearm, unlawful possession of a loaded firearm, unlawful possession of ammunition without a firearm identification card, and unauthorized use of a motor vehicle. Defendant filed a motion to suppress the handgun, the ammunition, and statements he made to police. The municipal court allowed the motion to suppress. The Supreme Judicial Court affirmed the order allowing the motion to suppress, holding (1) the police did not have probable cause to believe that Defendant was operating the vehicle he was driving in violation of Mass. Gen. Laws ch. 90, 24(2)(a), and therefore, the impoundment of the vehicle was not proper; and (2) therefore, the inventory search was not lawful, and the handgun and ammunition were properly suppressed. View "Commonwealth v. Campbell" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on a theory of deliberate premeditation, and of unlawful possession of a firearm for the shooting death of a fifteen year old boy. Defendant received the statutorily required sentence of life imprisonment without the possibility of parole for his murder conviction. Defendant was eighteen years old at the shooting. The Supreme Judicial Court affirmed, holding (1) the trial judge did not abuse her discretion in excluding from evidence a computer-generated simulation that was intended to assist the jury in determining the shooter’s height; (2) the remainder of the trial court’s evidentiary rulings challenged on appeal were not in error; (3) the Commonwealth did not improperly invoke the jury’s sympathy during closing argument; (4) Defendant’s sentence was not unconstitutional; and (5) there was no basis on which to grant Defendant extraordinary relief under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Chukwuezi" on Justia Law

Defendant was charged with murder in the first degree. A superior court judge allowed Defendant’s motion to suppress evidence recovered from his cellular telephone, concluding that the seizure of the telephone was not supported by probable cause. The Supreme Judicial Court affirmed, holding (1) probable cause to search or seize a person’s cellular telephone may not be based solely on an officer’s opinion or belief that the device is likely to contain evidence of the crime under investigation; (2) because the officers in this case lacked any information establishing the existence of relevant evidence likely to be found on Defendant’s telephone, the seizure was not supported by probable cause; and (3) the Commonwealth did not meet its burden of demonstrating that the sixty-eight-day-delay between the seizure and the application for a search warrant was reasonable. View "Commonwealth v. White" on Justia Law

After a jury trial, Defendant was convicted of two counts of criminal harassment. The convictions were based on five letters that Defendant wrote and sent to Michael and Susan Costello after a local election in which Michael had been elected as a town selectman. The Supreme Court reversed and dismissed Defendant’s conviction of criminal harassment of Michael and vacated Defendant’s conviction of criminal harassment of Susan and remanded for a new trial on that count, holding (1) in light of First Amendment constitutional protections afforded to political speech and the lack of evidence of serious alarm of Michael’s part, the evidence was not sufficient to support Defendant’s conviction of criminal harassment of Michael; and (2) the speech on which the complaint of criminal harassment of Susan is premised might be found to qualify as fitting within a constitutionally unprotected category of speech that may be subject to prosecution as a form of criminal harassment. View "Commonwealth v. Bigelow" on Justia Law