Justia Massachusetts Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of murder in the second degree and multiple firearms-related offenses. Defendant appealed, raising several claims. The Supreme Judicial Court reversed Defendant’s conviction of murder in the second degree and affirmed Defendant’s remaining convictions, holding (1) portions of the jury instructions concerning excessive force manslaughter were erroneous because they suggested that if Defendant used excessive force, the killing was murder and not manslaughter, and these errors were prejudicial; and (2) Defendant’s remaining arguments were without merit. Remanded for a new trial on the murder in the second degree charge. View "Commonwealth v. Allen" on Justia Law

After a jury trial, Defendant was convicted of trafficking in fourteen grams or more of cocaine. Defendant sought further review, arguing that the search of his genital area during a patfrisk for weapons was an unlawful strip search, and therefore, the motion judge erred in denying his motion to suppress the evidence obtained during the search. The Supreme Judicial Court reversed the denial of Defendant’s motion to suppress and vacated the judgment of conviction, holding that the search met the criteria for a strip search and did not satisfy the probable cause requirement articulated in Commonwealth v. Morales. Remanded. View "Commonwealth v. Amado" on Justia Law

Defendant was convicted on counts of an indictment charging two sentencing enhancements - one as a second-time offender and one under the Massachusetts armed career criminal (ACC) statute. Both enhancements were premised on an underlying conviction of unlawful possession of a sawed-off shotgun. Defendant was sentenced to a term of fifteen to seventeen years on the ACC enhancement and was not sentenced on the second offender enhancement. The Appeals Court reversed the ACC conviction and remanded for resentencing. On remand, Defendant sought to be sentenced under the enhancement statute, and the Commonwealth sought the imposition of a longer sentence under the underlying crime. The Commonwealth then entered a nolle prosequi of the second offender enhancement charge, and the judge sentenced Defendant to a term of from twelve to fifteen years on the underlying conviction. Defendant appealed, arguing that the judge erred in allowing the Commonwealth to avail itself of the nolle prosequi procedure after the initial sentencing had already occurred. The Supreme Judicial Court affirmed, holding that the Commonwealth was unable to exercise its nolle prosequi authority as to the second offender enhancement because that conviction was no longer available, and therefore, the resentencing judge was left to craft a sentence based only the only remaining charge - the underlying crime. View "Commonwealth v. Boyd" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on theories of deliberate premeditation and extreme atrocity or cruelty. The Supreme Judicial Court affirmed Defendant’s convictions and discerned no basis to exercise is authority pursuant to Mass. Gen. Laws ch. 278, 33E, holding (1) the trial judge did not err in denying Defendant’s three motions to suppress evidence stemming from the search of Defendant's clothing and shoes that were stored in a secured area while he was civilly committed for drug treatment; (2) there was no error in the presentation of DNA evidence; (3) the trial judge’s failure to give a diminished capacity instruction did not create a substantial likelihood of a miscarriage of justice; and (4) the trial judge did not abuse his discretion in making a juror bias determination. View "Commonwealth v. Cassino" on Justia Law

In Commonwealth v. Sylvain, the Supreme Judicial Court affirmed its decision in Commonwealth v. Clarke that defense counsel’s duty to provide noncitizen defendants with accurate advice regarding the deportation consequences of pleading guilty was to be applied retroactively on collateral review. The Court set the date of retroactivity at the effective date of the Illegal Immigration Reform and Immigrant Responsibility Act (IIRIRA). Defendant pleaded guilty to possession of a class A substance. Defendant’s guilty plea was entered after the effective date of the Antiterrorism and Effective Death Penalty Act (AEDPA) but before the effective date of the IIRIRA. Defendant filed a motion for a new trial alleging that his attorney provided ineffective assistance for failing to adequately advise him as to the likely deportation consequences of his guilty plea. The motion judge denied the motion. The Supreme Judicial Court vacated the denial, holding (1) the retroactivity affirmed in the Sylvain case should extend back to the effective date of AEDPA for certain convictions; and (2) because the motion judge in this case did not explain on what ground he based his denial of Defendant’s motion for a new trial, the matter is remanded for further proceedings. View "Commonwealth v. Mercado" on Justia Law

In Commonwealth v. Sylvain, the Supreme Judicial Court affirmed its decision in Commonwealth v. Clarke that defense counsel’s duty to provide noncitizen defendants with accurate advice regarding the deportation consequences of pleading guilty was to be applied retroactively on collateral review. The Court set the date of retroactivity at the effective date of the Illegal Immigration Reform and Immigrant Responsibility Act (IIRIRA). Defendant pleaded guilty to possession of a class A substance. Defendant’s guilty plea was entered after the effective date of the Antiterrorism and Effective Death Penalty Act (AEDPA) but before the effective date of the IIRIRA. Defendant filed a motion for a new trial alleging that his attorney provided ineffective assistance for failing to adequately advise him as to the likely deportation consequences of his guilty plea. The motion judge denied the motion. The Supreme Judicial Court vacated the denial, holding (1) the retroactivity affirmed in the Sylvain case should extend back to the effective date of AEDPA for certain convictions; and (2) because the motion judge in this case did not explain on what ground he based his denial of Defendant’s motion for a new trial, the matter is remanded for further proceedings. View "Commonwealth v. Mercado" on Justia Law

Appellant was found guilty of twenty-one counts of unauthorized access to a computer system. That same day Appellant filed an application for voluntary superannuation retirement. The public employment retirement administration commission concluded that Appellant's criminal convictions related to his office or position and, therefore, Appellant was not entitled to receive a retirement allowance under Mass. Gen. Laws ch. 32, 15(4). On review, a judge in the district court concluded that Appellant's convictions did not trigger forfeiture under section 15(4). The superior court affirmed. The Appeals Court vacated the judgment, concluding that Appellant's convictions were directly linked to his office or position, and remanded for consideration of Appellant's alternative argument that forfeiture of his pension constituted an excessive fine. On remand, the district court concluded that the fine in this case - forfeiture of Appellant's lifetime retirement allowance - was excessive and violated the Eighth Amendment. A superior court judge reversed. The Supreme Judicial Court reversed, holding (1) the mandatory forfeiture of a public employee’s retirement allowance upon conviction of a crime “involving violation of the laws applicable to his office or position” is a “fine” under the Eighth Amendment; and (2) under the circumstances of this case, the mandatory forfeiture of Appellant's public employee’s retirement allowance was “excessive.” View "Pub. Employee Ret. Admin. Comm’n v. Bettencourt" on Justia Law

Petitioner was convicted of forcible rape of a child and other offenses. Petitioner’s convictions were affirmed on appeal. Petitioner later filed a motion for a new trial, which a motion judge denied. Petitioner later filed a motion for an extension of time to file a late notice of appeal, but the motion was misplaced in the clerk’s office. When it was found, the motion judge granted the motion and gave Petitioner forty-five days to file his notice of appeal, but Petitioner did not file a new notice of appeal. When Petitioner filed a motion to file his brief late, he was informed that he had no matter pending in the Appeals Court. Petitioner then filed a petition for relief pursuant to Mass. Gen. Laws ch. 211, 3 or for relief in the nature of mandamus. A single justice of the Appeals Court denied all relief. The Supreme Judicial Court affirmed, holding that the single justice was not obligated to grant extraordinary relief. View "Cooper v. Commonwealth" on Justia Law

Defendant was convicted of murder in the first degree on a theory of felony-murder, based on the predicate felony of aggravated rape, and aggravated rape. Defendant was sentenced to concurrent terms of life in prison. The Supreme Judicial Court affirmed the conviction of murder of the first degree and ordered dismissal of the aggravated rape conviction as duplicative, holding (1) there was no error in the denial of Defendant’s motion for a required finding of not guilty; (2) the trial court correctly denied Defendant’s motion to suppress two statements Defendant made to police; (3) the trial court did not err in admitting testimony from the victim’s daughter; (4) there was no error in the admission into evidence of Defendant’s prior bad acts; (5) the prosecutor did not commit prejudicial misconduct during closing arguments; (6) the trial judge did not abuse his discretion in denying Defendant’s motion to reduce the verdicts; and (7) the conviction on the indictment alleging aggravated rape is duplicative of the conviction of felony-murder and must be dismissed. View "Commonwealth v. Mazariego" on Justia Law

Defendant was convicted of murder in the first degree on a theory of felony-murder, based on the predicate felony of aggravated rape, and aggravated rape. Defendant was sentenced to concurrent terms of life in prison. The Supreme Judicial Court affirmed the conviction of murder of the first degree and ordered dismissal of the aggravated rape conviction as duplicative, holding (1) there was no error in the denial of Defendant’s motion for a required finding of not guilty; (2) the trial court correctly denied Defendant’s motion to suppress two statements Defendant made to police; (3) the trial court did not err in admitting testimony from the victim’s daughter; (4) there was no error in the admission into evidence of Defendant’s prior bad acts; (5) the prosecutor did not commit prejudicial misconduct during closing arguments; (6) the trial judge did not abuse his discretion in denying Defendant’s motion to reduce the verdicts; and (7) the conviction on the indictment alleging aggravated rape is duplicative of the conviction of felony-murder and must be dismissed. View "Commonwealth v. Mazariego" on Justia Law