Justia Massachusetts Supreme Court Opinion Summaries
Articles Posted in Criminal Law
Commonwealth v. Cole
After a jury trial, Defendant was convicted of murder in the first degree on theories of deliberate premeditation, extreme atrocity or cruelty, and felony-murder. The Supreme Judicial Court affirmed Defendant’s convictions and declined to grant relief pursuant to Mass. Gen. Laws ch. 278, 33E, holding (1) the trial judge did not err in admitting medical records and related testimony and by instructing the jury on consciousness of guilt; (2) the trial judge did not err in admitting expert testimony concerning the statistical significance of DNA evidence; (3) the trial judge did not err by admitting the victim’s T-shirt into evidence, despite a purported discovery violation by the Commonwealth; (4) the prosecutor did not commit misconduct during her opening statement or her closing argument; and (5) the trial judge properly denied Defendant’s motion for required findings of not guilty. View "Commonwealth v. Cole" on Justia Law
Souza v. Commonwealth
Petitioner was convicted of four counts of violating an abuse prevention order. Petitioner’s direct appeal was entered in the Appeals Court and was pending there when he filed a pleading in the county court entitled “Petition to Remand Sentence for Resentencing.” In the petition, Petitioner asserted that his sentences were unduly harsh and that his trial counsel provided ineffective assistance. A single justice denied the petition without a hearing. The Supreme Judicial Court affirmed, holding that a defendant is not entitled to the extraordinary intervention of the Supreme Judicial Court to vacate or change a sentence that is legal but that the defendant feels is too harsh. View "Souza v. Commonwealth" on Justia Law
Posted in:
Criminal Law
Doe v. Sex Offender Registry Board
Plaintiff was found guilty of indecent assault and battery on a child under fourteen. While Plaintiff was still incarcerated, the Sex Offender Registry Board (SORB) recommended that Plaintiff be classified as a level three sex offender. Plaintiff challenged the recommendation. A SORB hearing officer determined by a preponderance of the evidence that Plaintiff was appropriately classified as a level two offender. The superior court affirmed the level two classification. At issue before the Supreme Judicial Court was the standard of proof that the SORB must satisfy in order to classify a convicted sex offender under the provisions of the sex offender registry law. The Supreme Judicial Court vacated the decision of the superior court affirming SORB’s classification of Plaintiff as a level two sex offender, holding that due process requires that a sex offender’s risk level be proved by clear and convincing evidence. Remanded for entry of an order to SORB to conduct an evidentiary hearing de novo under the heightened standard. View "Doe v. Sex Offender Registry Board" on Justia Law
Posted in:
Criminal Law, Government & Administrative Law
Chin v. Commonwealth
A petition for Defendant’s civil commitment as a sexually dangerous person was pending in the superior court. Defendant assented to a finding of probable cause and was temporarily committed for examination and diagnosis by two qualified examiners. The examiners submitted their reports, and the Commonwealth petitioned for trial. Defendant petitioned for relief under Mass. Gen. Laws ch. 211, 3 from the trial judge’s denial of Defendant’s motion in limine to preclude the Commonwealth from calling certain witnesses. A single justice of the Supreme Judicial Court denied the petition. The Supreme Judicial Court affirmed, holding that because Defendant had alternative remedies available to him, the single justice did not err by denying extraordinary relief. View "Chin v. Commonwealth" on Justia Law
Posted in:
Criminal Law
Brea v. Commonwealth
The district court issued a complaint charging Defendant with distribution of heroin and conspiracy to violate the drug laws. Prior to arraignment, Defendant moved to dismiss the complaint. A district court judge denied the motion, ruling that there was probable cause to issue the complaint. Defendant subsequently filed a Mass. Gen. Laws ch. 211, 3 petition seeking relief from this ruling. A single justice of the Supreme Judicial Court denied the petition without a hearing. The Supreme Judicial Court affirmed, holding that the district court’s ruling did not present an exceptional circumstances warranting exercise of the Court’s extraordinary superintendence powers. View "Brea v. Commonwealth" on Justia Law
Posted in:
Criminal Law
Sliney v. Previte
In 2012, Plaintiff filed an action alleging that Defendant had sexually abused her between 1968 and 1977, when she was a child. Until June 2014, civil actions alleging sexual abuse of a minor were governed by a three-year statute of limitations. See Mass. Gen. Laws ch. 260, 4C. Section 4C was amended effective June 2014 to extend the limitations period to thirty-five years. The superior court in this case dismissed the complaint on statute of limitations grounds. The Supreme Judicial Court vacated the judgment of the superior court, holding (1) under the circumstances of this case, section 4C’s extended statute of limitations applies to Plaintiff’s case; and (2) the retroactive application is constitutional as applied to Defendant. Remanded. View "Sliney v. Previte" on Justia Law
Posted in:
Criminal Law
Commonwealth v. Tejeda
After a jury trial, Defendant was convicted of murder in the second degree on the theory of felony-murder, with armed robbery as the underlying felony. The trial judge allowed Defendant’s motion for a required finding of not guilty on the felony-murder conviction. At issue on appeal was whether a defendant who joins with others to commit an armed robbery may be found guilty of murder on the theory of felony-murder for the killing of his accomplice by someone resisting the armed robbery. The Supreme Judicial Court affirmed the judge’s order allowing Defendant’s motion for a required finding of guilty on the indictment charging felony-murder in the second degree, holding that a defendant cannot be held criminally liable for the death of any person killed by someone resisting the commission of the felony. View "Commonwealth v. Tejeda" on Justia Law
Posted in:
Criminal Law
Field v. Commonwealth
After a trial, Defendant was convicted of murder in the first degree. Defendant appealed. Defendant also filed a motion for a new trial, arguing that she was deprived of the effective assistance of trial counsel. Defendant’s appeal was stayed pending resolution of her motion for a new trial. On the Commonwealth’s motions, the trial judge ordered that trial counsel be summonsed to testify at the hearing on Defendant’s motion and that Defendant provide the Commonwealth with certain discovery. Defendant subsequently filed a petition pursuant to Mass. Gen. Laws ch. 211, 3 seeking relief from these orders. A single justice of the Supreme Judicial Court denied extraordinary relief. The Supreme Judicial Court affirmed, holding that Defendant had an adequate alternative remedy by way of appeal from any adverse ruling on the motion for a new trial. View "Field v. Commonwealth" on Justia Law
Commonwealth v. Garrett
After a jury trial, Defendant was convicted on three indictments charging armed robbery with a firearm while masked. Defendant used a BB gun to perpetrate each of the robberies. Defendant appealed, arguing that the evidence was insufficient to support his conviction. The Supreme Judicial Court vacated Defendant’s convictions for armed robbery by means of a firearm, holding that a BB gun does not satisfy the statutory requirement of a “firearm” within the meaning of the armed robbery statute. Remanded to the superior court for entry of judgments of guilt on the lesser included offense of unarmed robbery. View "Commonwealth v. Garrett" on Justia Law
Posted in:
Criminal Law
Commonwealth v. Watkins
After a jury trial, Defendant was found guilty of murder in the first degree. The Supreme Judicial Court affirmed the convictions and the trial court’s denial of Defendant’s motion for a new trial and declined to reduce the degree of guilt pursuant to Mass. Gen. Laws ch. 278, 33E, holding (1) there was sufficient evidence to sustain Defendant’s conviction; (2) Defendant suffered no prejudice as a result of the Commonwealth’s failure to disclose certain evidence; (3) there was no error due to the Commonwealth’s exclusion of third-party culprit evidence; (4) the judge judge did not abuse her discretion in denying Defendant’s motion to exclude hearsay statements by the victim’s girl friend; (5) the prosecutor did not engage in impermissible misconduct; (6) defense counsel’s performance was not constitutionally deficient; and (7) Defendant failed to establish that a new trial was required because the prosecutor had represented him on several previous occasions. View "Commonwealth v. Watkins" on Justia Law