Justia Massachusetts Supreme Court Opinion Summaries

Defendants were charged with shoplifting by concealing merchandise and unlawfully carrying a firearm. Defendants moved to suppress the firearm discovered during the inventory search of the vehicle that they used to travel to the department store. The vehicle was lawfully parked in the department store lot, and, after Defendants were arrested for shoplifting, the driver of the vehicle told the police that the registered owner of the vehicle could pick up the vehicle as an alternative to having it towed. The motion judge allowed Defendants’ motion to suppress, concluding that the seizure of the vehicle that preceded the inventory search was not reasonable. The Supreme Judicial Court affirmed, holding that it was unreasonable and, thus, unconstitutional to impound the vehicle and conduct an inventory search where the driver offered the police an alternative to impoundment that was lawful and practical under the circumstances. View "Commonwealth v. Oliveira" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on a theory of extreme atrocity or cruelty and other crimes. Defendant appealed, arguing that the judge’s instruction on diminished capacity improperly limited the jury’s consideration of the evidence of his intoxication and, consequently, did not allow the jury to consider evidence of his diminished capacity from his intoxication with reference to whether the shooting was committed with extreme atrocity or cruelty. In the alternative, Defendant argued that the Supreme Judicial Court should adopt a specific intent requirement for murder committed with extreme atrocity or cruelty. The Court affirmed, holding (1) the instruction correctly conveyed to the jury that the effect upon Defendant of his intoxication was relevant to the Commonwealth’s burden to prove that Defendant acted in a cruel or atrocious manner; and (2) the instruction as given complies with current state of the law and was not erroneous. View "Commonwealth v. Boucher" on Justia Law

After a jury trial, Defendant was found guilty of murder in the first degree. During the pendency of his appeal, Defendant filed a motion for a new trial, alleging that he had not been competent to stand trial. The motion judge denied the motion after a nonevidentiary hearing. The Supreme Court reversed and remanded for an evidentiary hearing. After four days of evidentiary hearings, the motion judge again denied Defendant’s motion. The Supreme Judicial Court affirmed Defendant’s conviction and the denial of his motion for a new trial and declined to exercise its authority under Mass. Gen. Laws ch. 278, 33E, holding (1) Defendant failed to establish by a preponderance of the evidence that the Commonwealth would not have been able to meet its burden at a competency proceeding had the issue been raised prior to or at trial; and (2) therefore, Defendant’s motion for a new trial was correctly denied, and, as this was the only issue raised by Defendant in his appeal, the judgment stands. View "Commonwealth v. Chatman" on Justia Law

Defendant, who is not a citizen of the United States, pleaded guilty to one count of possession of cocaine. Defendant was subsequently placed in a removal proceeding. Defendant filed a motion to vacate his guilty plea, claiming that he received ineffective assistance from his plea counsel when counsel provided erroneous advice that Defendant would not be subject to deportation. The motion was denied. The Supreme Judicial Court concluded that Defendant received ineffective assistance of plea counsel and remanded the matter for additional findings relating to the issue of prejudice. On remand, the judge allowed Defendant’s motion to vacate his guilty plea and ordered a new trial. The Supreme Judicial Court affirmed, holding (1) the judge did not abuse his discretion in allowing Defendant’s motion for a new trial; and (2) the affidavits of Defendant and his plea counsel provided a sufficient basis to conclude that, but for counsel’s errors, Defendant would not have pleaded guilty and would have decided instead on going to trial. View "Commonwealth v. Sylvain" on Justia Law

Petitioner pleaded guilty in a Connecticut court to a sex crime. As conditions of his probation, Petitioner was ordered not to leave Connecticut and to submit to electronic monitoring. Petitioner’s supervision was later transferred to Massachusetts, and a Connecticut judge ordered GPS monitoring be at the discretion of the Massachusetts Department of Probation. Thereafter, Petitioner requested that he not be subjected to mandatory GPS monitoring and that he be considered for travel permits to certain states. The Massachusetts Commissioner of Probation largely denied the request. After Petitioner was found in violation of probation conditions by a Connecticut judge, Petitioner filed a petition in the pursuant to Mass. Gen. Laws ch. 211, 3 seeking relief from the orders of the Commissioner. The Supreme Judicial Court held (1) where a petitioner argues that a special condition of probation that was added by Massachusetts is not mandated by Massachusetts law or is unconstitutional, this determination should be made by a Massachusetts court through a complaint for declaratory relief; (2) the Massachusetts may not add mandatory GPS monitoring as a special condition of probation for Petitioner; and (3) the prohibition on out-of-state travel for probationers being supervised for sex offenses is not an additional condition of probation imposed on a transferred probationer. View "Goe v. Comm’r of Probation" on Justia Law

After a jury trial, Defendant was found guilty of attempted armed robbery and murder in the first degree on theories of extreme atrocity or cruelty and felony murder. Defendant was sentenced to life imprisonment on the murder charge. Defendant appealed, challenging the admission into evidence of his videotaped statement to the police and a statement he made while he was left alone during the police interrogation. Specifically, Defendant argued that although he initially waived his Miranda rights, he later invoked his right to remain silent and that the police did not scrupulously honor this invocation. Defendant failed to raise this claim below. The Supreme Judicial Court reversed Defendant’s convictions, holding that the police’s failure to honor Defendant’s right to terminate questioning created a substantial likelihood of a miscarriage of justice because the statement was likely to have affected the jury’s verdict. View "Commonwealth v. Smith" on Justia Law

Defendant was charged with attempted murder and related assault and battery and child endangerment crimes for not giving prescribed chemotherapy and other medications designed to treat the cancer from which her son ultimately died. The Supreme Judicial Court affirmed Defendant’s conviction of reckless child endangerment but reversed the judgments on the assault and battery charges and the order denying Defendant’s motion for a new trial on the charge of attempted murder, holding (1) the judge’s instructions correctly explained the elements of attempted murder, and nonachievement of murder is not an element of attempted murder; (2) the trial evidence was insufficient to permit convictions of the two assault and battery charges, and the judge’s instructions were legally incorrect; and (3) the judge erred in denying Defendant’s motion for a new trial on the ground of ineffective assistance of counsel. Remanded. View "Commonwealth v. LaBrie" 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. Defendant subsequently filed a motion for a new trial based on alleged trial errors. The motion was denied after an evidentiary hearing. The Supreme Judicial Court affirmed the order denying Defendant’s motion for new trial as well as Defendant’s conviction and discerned no basis to exercise its authority pursuant to Mass. Gen. Laws ch. 278, 33E, holding (1) the trial court erroneously admitted certain DNA evidence, but there was no substantial likelihood of a miscarriage of justice; (2) trial counsel was not ineffective for introducing audiotapes of prior consistent statements made by the Commonwealth’s principal witness for impeachment purposes; (3) there was no substantial likelihood of a miscarriage of justice created by the admission of a cooperating codefendant’s plea agreement without prior redaction; (4) there was no error in the admission of prior bad act evidence; and (5) trial counsel did not provide ineffective assistance. View "Commonwealth v. Lally" on Justia Law

Defendant was charged with reckless endangerment of a child by walking on railroad tracks with a child. The trial judge dismissed the count of reckless endangerment, concluding (1) the Commonwealth was required to establish that Defendant was actually aware of the substantial risk of serious bodily injury to which he exposed his child, and (2) sufficient evidence was not presented in the application for the criminal complaint to establish probable cause to believe Defendant had the requisite mental state. The Supreme Court vacated the order of dismissal, holding (1) the trial judge correctly stated the law; and (2) the probable cause requirement was satisfied in this case. View "Commonwealth v. Coggeshall" on Justia Law

Defendant was convicted of armed robbery while masked, kidnapping for purposes of extortion, and armed assault with intent to murder. The Appeals Court affirmed the convictions. Defendant appealed, arguing that the trial court erred in denying his motion to suppress his cellular telephone records. Specifically, Defendant contended that the government failed to comply with Mass. Gen. Laws ch. 271, 17B, as then in effect, in obtaining his telephone records. The Supreme Judicial Court affirmed, holding that Mass. Gen. Laws ch. 271, 17B, as then in effect, did not preclude the government from obtaining the records at issue in this case, and therefore, Defendant’s motion to suppress the records was correctly denied. View "Commonwealth v. Chamberlin" on Justia Law