Justia Massachusetts Supreme Court Opinion Summaries

Petitioner was convicted of murder in the first degree. Petitioner was a juvenile when the crime was committed. Thirty years later, the Supreme Judicial Court determined that any juvenile offender who had been convicted of murder in the first degree and sentenced to life in prison without the possibility of parole became eligible for parole within sixty days before the expiration of fifteen years of his life sentence. Therefore, Petitioner became immediately eligible to be considered for parole. Four out of seven members of the parole board panel voted in favor of parole. The parole board refused to grant a parole permit because, pursuant to a 2012 amendment to Mass. Gen. Laws ch. 127, 133A, a parole permit can only be granted by a vote of two-thirds of the parole board members on the panel. Petitioner appealed, arguing that the application of the amendment to his parole determination, rather than the version in effect at the time he committed the crime, was an ex post facto violation. The Supreme Judicial Court reversed the parole board’s decision, holding (1) the supermajority amendment was applied retroactively to Petitioner; and (2) the amendment was, as applied to Petitioner, an ex post facto violation. View "Clay v. Massachusetts Parole Board" on Justia Law

Defendant was convicted of criminal offenses in 2008. The Appeals Court affirmed. In 2012, the trial judge granted Defendant’s second motion for a new trial. The Appeals Court reversed, effectively reinstating Defendant’s convictions. The Supreme Judicial Court denied Defendant’s application for further appellate review. Defendant then filed a petition in the county court requesting that the single justice stay the reinstatement of his sentences pending a ruling on a petition for certiorari that he had filed in the United States Supreme Court. The single justice denied the petition. The Supreme Judicial Court affirmed, holding that the single justice correctly denied the petition. View "Felton v. Commonwealth" on Justia Law

Defendant pleaded guilty to two counts of distribution of cocaine. The substances were subsequently tested at the William A. Hinton State Laboratory Institute, and Annie Dookhan was one of two assistant analysts who signed the drug certificates. After Dookhan’s misconduct had been discovered, Defendant moved for a new trial, seeking to vacate his guilty pleas on the ground of Dookhan’s misconduct. The trial court denied the motion. The Supreme Judicial Court affirmed, holding that there was no basis to find that governmental misconduct occurred prior to the acceptance of Defendant’s guilty pleas or that any governmental misconduct rendered Defendant’s guilty pleas unintelligent or involuntary. View "Commonwealth v. Ruffin" on Justia Law

Defendant admitted to facts sufficient to warrant a finding of guilty to stealing the property of Walmart having a value of more than $250 pursuant to a single larcenous scheme. At a restitution hearing, the judge declared that Walmart’s loss was measured by the retail loss and ordered that Defendant pay $5,256 in restitution. The Supreme Judicial Court vacated the judge’s restitution order, holding (1) in determining whether to impose restitution and the amount of restitution, a judge must consider a defendant’s ability to pay, and in this case, the judge erred in failing to consider Defendant’s ability to pay in determining whether to order restitution and in determining the amount of restitution; and (2) in cases of retail theft, the amount of actual economic loss for purposes of restitution is the replacement value of the stolen goods unless the Commonwealth proves that the stolen goods would otherwise have been sold, in which case the retail sales value is the measure of actual loss, and in this case, the judge did not err in determining that the appropriate amount of Walmart’s actual loss was the aggregate retail price of the items stolen. Remanded. View "Commonwealth v. Henry" on Justia Law

In a probation surrender proceeding based on the use of marijuana, purportedly for medical purposes, the judge found Defendant in violation of probation for the use of marijuana, terminated his probation, and imposed a prison sentence. Defendant, who was a qualifying patient under the medical marijuana law (act), appealed, arguing (1) his sentence violated his right to the medical use of marijuana without adverse legal consequences, and (2) counsel provided ineffective assistance by failing to assert the immunity provision of the act. The Supreme Judicial Court affirmed, holding (1) under the circumstances of this case, the judge did not err in finding Defendant in violation of his probation; and (2) there was no prejudice in counsel’s stipulating to the violation without raising the issue as a defense to the violation. View "Commonwealth v. Vargas" on Justia Law

District court judges ordered the two defendants in these consolidated cases to pretrial detention under the dangerousness statute, Mass. Gen. Laws ch. 276, 58A, under which a person “held under arrest” on charges of one of an enumerated list of offenses may be subject to a pretrial detention hearing. Defendants both argued that they were not “held under arrest” within the meaning of the statute when they appeared in court to be arraigned and, therefore, could not lawfully be subjected to a pretrial detention hearing. The Supreme Judicial Court affirmed the orders of pretrial detention, holding that where a criminal defendant has been arrested or is subject to an outstanding arrest warrant for an enumerated offense, he or she may be subject to pretrial detention under the dangerousness statute, even if the defendant is not held in custody following the arrest, so long as the dangerousness hearing takes place immediately upon the defendant’s first appearance before the court. View "Commonwealth v. Diggs" on Justia Law

After a jury trial in 1997, Petitioner was convicted of murder in the first degree on a theory of felony murder. Petitioner later filed a motion in the superior court seeking postconviction testing of biological material pursuant to Mass. Gen. Laws ch. 278A, 3. The superior court judge denied Petitioner’s motion for scientific testing. Petitioner then filed a petition seeking leave to appeal from the denial of his motion for forensic and scientific testing. The Supreme Judicial Court reversed, holding that Petitioner demonstrated that the requested analysis had not yet been developed at the time of his conviction and therefore met the requirement to establish one of the five enumerated reasons explaining why the requested testing was not previously conducted, and therefore, the trial judge erred in denying Petitioner’s motion. View "Commonwealth v. Wade" on Justia Law

Defendant was indicted on several drug-related charges. Defendant filed a motion to suppress items found during a search of his bag following his arrest on an outstanding warrant. The superior court allowed Defendant’s motion to suppress, concluding that there was no probable cause to search the bag as incident to Defendant’s arrest on the outstanding warrant. The Supreme Judicial Court affirmed the order allowing Defendant’s motion to suppress, holding that, under the totality of the circumstances, it was unreasonable for the police officers to seize the bag, and therefore, any subsequent search, even conducted pursuant to a lawful inventory search policy, was tainted by the unlawful seizure. View "Commonwealth v. Abdallah" on Justia Law

Defendant was convicted of murder in the first degree on a theory of deliberate premeditation in the shooting death of his former wife. The Supreme Judicial Court affirmed the convictions, holding (1) the trial judge did not abuse her discretion in allowing the admission of evidence of prior bad acts; (2) the prosecutor did not commit error during closing arguments; (3) the trial judge did not err in denying Defendant’s motion for a mistrial after learning that three jurors had discussed the case before deliberations began; and (4) the Court declines to exercise its power under Mass. Gen. Laws ch. 278, 33Ea to reduce the verdict of murder in the first degree to a lesser degree of guilt. View "Commonwealth v. Philbrook" on Justia Law

Defendant was indicted for several drug offenses. Defendant filed a motion for issuance of a subpoena seeking certain data he claimed would be relevant to support his claim that he was subjected to selective enforcement and racial profiling. A superior court judge denied the motion. Thereafter, Defendant filed a petition for relief under Mass. Gen. Laws ch. 211, 3. A single justice in the county court denied the petition without a hearing. The Supreme Judicial Court affirmed, holding that the single justice neither erred nor abused his discretion by denying extraordinary relief. View "Martinez v. Commonwealth" on Justia Law