Justia Massachusetts Supreme Court Opinion Summaries
Articles Posted in Criminal Law
Commonwealth v. Adonsoto
After a jury trial, Defendant was convicted of operating a motor vehicle while under the influence of intoxicating liquor. The Supreme Judicial Court affirmed the conviction, holding (1) the trial court did not err in admitting evidence of Defendant’s failure to properly perform a breathalyzer test after giving consent, as the evidence was not inadmissible as refusal evidence; (2) the admission of the police-appointed interpreter’s English language version of Defendant’s statements did not violate the rule against hearsay, as the interpreter acted as Defendant’s agent under the circumstances of this case; (3) Defendant’s unpreserved confrontation claim was unavailing; (4) the evidence was sufficient to establish Defendant’s impairment; and (5) there was no prejudicial error in the jury instructions. View "Commonwealth v. Adonsoto" on Justia Law
Commonwealth v. Teixeira
Defendants in these two criminal cases were charged in the Boston Municipal Court (BMC) with a number of felonies. The BMC judges scheduled probable cause hearings for Defendants to determine whether there was sufficient evidence to bind them over to the Superior Court for trial and ordered the Commonwealth to provide Defendants with discovery in advance of those hearings. The Commonwealth objected to the discovery orders, arguing that the BMC and the District Court Department are not explicitly authorized to order discovery in preparation for probable cause hearings. The Supreme Judicial Court affirmed, holding (1) judges of the BMC may, in their discretion, order preheating discovery; and (2) the judges in this case did not abuse their discretion by issuing the discovery orders. View "Commonwealth v. Teixeira" on Justia Law
Posted in:
Criminal Law
Commonwealth v. Baratieri
Two individuals (“the Sureties”) acted as sureties for Defendant and posted bail on his behalf. The Sureties filed a motion for return of bail on the basis that Defendant could not appear for a hearing because he was in federal custody on an immigration and customs enforcement detainer. The motion was denied. After Defendant failed to appear for the hearing, the judge ordered the bail forfeited. The Sureties filed a petition pursuant to Mass. Gen. Laws ch. 211, 3 in the county court asking the court to order return of bail. A single justice denied the petition. The Supreme Judicial Court affirmed, holding that this case did not present the type of exceptional circumstance that requires the exercise of the Court’s extraordinary power of general superintendence pursuant to Mass. Gen. Laws ch. 211, 3. View "Commonwealth v. Baratieri" on Justia Law
Posted in:
Criminal Law
Vinnie v. Commonwealth
In 1993, Defendant was convicted of first degree murder. Defendant’s convictions were affirmed on appeal. After unsuccessfully filing numerous postconviction petitions, Defendant filed in the county court a petition in the nature of mandamus pursuant to Mass. Gen. Laws ch. 249, 5. A single justice denied the petition, concluding that mandamus relief was not appropriate because Defendant had another adequate remedy. Defendant filed a notice of appeal. The Supreme Judicial Court affirmed, holding that, regardless of whether the Court considered the petition pursuant to Mass. Gen. Laws ch. 249, 5 or Mass. Gen. Laws ch. 278, 33E, Defendant was not entitled to relief. View "Vinnie v. Commonwealth" on Justia Law
Posted in:
Criminal Law
Commonwealth v. Ellis
After a jury trial, Defendant was found guilty of murder in the first degree and armed robbery. The Supreme Court affirmed. This appeal concerned Defendant’s second motion for a new trial based on newly discovered evidence. The superior court judge allowed the motion for a new trial, ruling that the newly discovered evidence was material, credible, and would have been a real factor in the jury’s deliberations such that this was a case where justice had not been done. The Supreme Judicial Court affirmed, holding that the motion judge did not abuse her discretion in ruling that the newly discovered evidence warranted a new trial. View "Commonwealth v. Ellis" on Justia Law
Posted in:
Criminal Law
Commonwealth v. Snyder
After a jury trial, Defendant was convicted of murder in the first degree on a theory of deliberate premeditation. Defendant appealed his conviction and also sought relief under Mass. Gen. Laws ch. 278, 33E asking that his sentence be revised. The Supreme Judicial Court affirmed, holding (1) the trial judge did not err in not allowing the admission of testimony by an expert on eyewitness identification or in allowing the admission of testimony concerning a stocking cap that was seized from a vehicle Defendant was driving several months after the shooting; and (2) there was no reason to exercise the Court’s authority to grant extraordinary relief, but because Defendant’s pending motion to revise and revoke his sentence was timely filed but has not been acted upon, the matter is remanded to the superior court for consideration of the motion. View "Commonwealth v. Snyder" on Justia Law
Posted in:
Criminal Law
Commonwealth v. DiBenedetto
After a second trial, a jury found Defendant guilty of two counts of murder in the first degree. Defendant later filed a motion for a new trial on the basis of new DNA evidence. The motion judge denied the motion without a hearing. Defendant filed a gatekeeper petition pursuant to Mass. Gen. Laws ch. 278, 33E, and was granted leave to appeal the denial of the motion to the full court. The Supreme Judicial Court vacated the order denying the motion and remanded for further findings. After a nonevidentiary hearing, the motion judge again denied Defendant’s motion for a new trial. Defendant filed a notice of appeal and a petition in the county court to reinstate his appeal in the full court. A single justice treated Defendant’s petition to reinstate his appeal as a second gatekeeper petition and denied the petition. Defendant then filed a motion in the full court to reinstate his appeal. The Supreme Judicial Court affirmed the order denying Defendant’s motion for a new trial, holding (1) the reinstatement of Defendant’s appeal was appropriate; and (2) the motion judge did not abuse his discretion in denying Defendant’s motion for a new trial. View "Commonwealth v. DiBenedetto" on Justia Law
Posted in:
Criminal Law
Commonwealth v. Gonzalez
After a jury trial, Defendant was convicted as a joint venturer of murder in the first degree on a theory of deliberate premeditation. The conviction was based on evidence that Defendant had been the driver of the vehicle that dropped off at an intersection four people who shot the victim. Defendant appealed, arguing that the trial judge erred in denying her motion for a required finding of not guilty. The Supreme Judicial Court reversed, holding that Defendant’s motion for a required finding of not guilty should have been granted because the evidence was insufficient to allow a jury to conclude, beyond a reasonable doubt, that Defendant was the driver of the vehicle or that she was in some way involved in the shooting. View "Commonwealth v. Gonzalez" on Justia Law
Posted in:
Criminal Law
Commonwealth v. Vargas
After a jury trial, Defendant was convicted of murder in the first degree on a theory of extreme atrocity and cruelty. Defendant appealed. The Supreme Judicial Court vacated Defendant’s conviction of murder in the first degree and his sentence, holding (1) the trial court did not commit any errors that would warrant a new trial; but (2) under the circumstances of this case, a reduction of Defendant’s conviction from murder in the first degree to voluntary manslaughter was more consonant with justice. Remanded for the entry of a verdict of guilty of voluntary manslaughter and for imposition of sentence. View "Commonwealth v. Vargas" on Justia Law
Posted in:
Criminal Law
Massachusetts v. Herndon
The City of Springfield filed suit against the City of Papillion, and Sarpy County, seeking to enjoin Papillion from annexing land which had been indicated as Springfield’s area of future growth in a map adopted by the County in 1995. The district court for Sarpy County found that Springfield lacked standing; Springfield appealed. After review, the Nebraska Supreme Court found that Springfield asserted an infringement of its statutory governmental functions and rights under the County Industrial Sewer Construction Act. That infringement was sufficient to grant standing. The Court reversed the district court and remanded the case for further proceedings. View "Massachusetts v. Herndon" on Justia Law
Posted in:
Constitutional Law, Criminal Law