Justia Massachusetts Supreme Court Opinion Summaries

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

In 2007, Defendant pleaded guilty on indictments charging several drug-related offenses. In 2012, Defendant filed a motion to withdraw his guilty pleas based on the misconduct of Annie Dookhan, a chemist who was employed in the forensic drug laboratory of the William A. Hinton State Laboratory Institute from 2003 until 2012. Prior to the issuance of a ruling on Defendant’s motion, the Supreme Court decided Commonwealth v. Scott, in which the Court articulated a framework for analyzing a defendant’s motion to withdraw a guilty plea in a case involving Dookhan’s malfeasance. In light of Scott, as well as new evidence, Defendant filed supplemental pleadings in 2014 in support of his motion to withdraw his guilty pleas. The superior court denied Defendant’s motion to withdraw his guilty pleas. The Supreme Judicial Court affirmed, holding that Defendant was not entitled to the conclusive presumption established in Scott that egregious government misconduct occurred in his case, and therefore, Defendant’s motion to withdraw his guilty pleas was properly denied. View "Commonwealth v. Resende" on Justia Law

After a trial, Defendant was found guilty of the trafficking and distribution of cocaine. During trial, drug certificates were admitted into evidence that were signed by Annie Dookhan declaring that the substances in question were cocaine and that set forth their weight. Six years after the jury returned their guilty verdicts, Defendant filed a motion for a new trial, alleging that he was entitled to a new trial because of newly discovered evidence arising from Dookhan’s misconduct in conducting drug analyses. The trial judge denied the motion. The Appellate Court affirmed. The Supreme Judicial Court vacated Defendant’s convictions and remanded for a new trial, holding (1) a defendant found guilty at trial who moves for a new trial is entitled to the same conclusive presumption of “egregious government misconduct” that the Court applied in Commonwealth v. Scott to cases where a defendant seeks to withdraw his guilty plea after learning of Dookhan’s misconduct; and (2) the trial court in this case erred in admitting the drug certificates regarding Dookhan’s drug analysis, and the Commonwealth did not meet its burden of proving that the admission of the drug certificates did not influence the jury or had only a slight effect on their verdicts. View "Commonwealth v. Francis" on Justia Law

Defendant was sixteen years old at the time he admitted to committing murder. Defendant made his confession after prolonged questioning by the police and by his mother. Defendant filed a motion to suppress his statements to the police, but the motion was denied. After a jury trial, Defendant was convicted of murder in the first degree on the theory of deliberate premeditation and unlicensed possession of a firearm. Defendant filed a motion for a new trial, alleging that he was denied the effective assistance of counsel. Defendant’s claims were denied, and the denial of his motion was consolidated with his direct appeal. The Supreme Judicial Court affirmed Defendant’s convictions and declined to grant relief under Mass. Gen. Laws ch. 278, 33E, holding (1) the Court declines to expand the rule requiring the corroboration of extrajudicial statements as it applies to juvenile confessions; (2) the trial court did not err by denying Defendant’s motion for a new trial; (3) the trial court did not err by denying Defendant’s motion to suppress on the grounds asserted by Defendant; and (4) the trial court did not err by denying Defendant’s motion for a directed verdict on the firearms charge. View "Commonwealth v. Weaver" on Justia Law