Justia Massachusetts Supreme Court Opinion Summaries

The defendant was convicted of reckless endangerment of a child and witness intimidation after attacking her twelve-year-old son. The incident began with an argument about the son's dental braces, leading the defendant to contemplate suicide. The next morning, she attempted to kill her son by stabbing him in the neck and trying to drown him. The son managed to escape and tried to call 911, but the defendant took his phone and told the dispatcher everything was fine. The son eventually called the police, who found him injured and the defendant attempting to harm herself.The defendant was indicted on multiple charges, including assault and battery by means of a dangerous weapon and attempted murder. After a bench trial, the Superior Court judge found her not guilty by reason of mental illness for the assault and attempted murder charges but guilty of reckless endangerment and witness intimidation. She was sentenced to five years of probation with conditions, including no unsupervised contact with her children and GPS monitoring for two years. The defendant appealed, and the Supreme Judicial Court granted direct appellate review.The Supreme Judicial Court upheld the convictions, finding sufficient evidence that the defendant was criminally responsible for her actions after the attack. The court determined that the defendant understood the criminality of preventing her son from calling 911 and could conform her conduct to the law. The court also found the indictment for reckless endangerment was not impermissibly ambiguous and that the GPS monitoring condition of probation was reasonable. The court affirmed the convictions and the probation condition. View "Commonwealth v. Rezac" on Justia Law

In November 2004, a sixteen-year-old juvenile stalked and robbed a victim at gunpoint, repeatedly raped her in her home, and then bound, gagged, and robbed her roommate when she arrived. He was sentenced to state prison for aggravated rape and other offenses, with a period of parole ineligibility compliant with constitutional requirements. After serving his prison term, he was placed on probation for the remaining nonhomicide offenses.In March 2007, the juvenile was adjudicated as a youthful offender and sentenced to sixteen to twenty years in state prison for aggravated rape, with additional concurrent and consecutive sentences for other offenses. In 2021, following a court decision, his sentence was restructured to comply with constitutional requirements, reducing his parole ineligibility to fifteen years. He was released from prison in January 2022 and began a five-year probation term. In August 2022, he was arrested for new offenses, leading to a probation violation notice and detention.The Supreme Judicial Court of Massachusetts reviewed the case. The court held that the restructured sentence, including the probation term, did not violate constitutional protections against cruel or unusual punishment. The court emphasized that the probation term provided the juvenile with an opportunity for rehabilitation and reintegration into the community. The court also noted that any potential further incarceration resulting from a probation violation would be subject to constitutional constraints, ensuring that the juvenile would not be treated more harshly than a juvenile convicted of murder for parole eligibility purposes. The court affirmed the order denying the juvenile's motion for relief from unlawful restraint. View "Commonwealth v. Sajid S." on Justia Law

The case involves a juvenile who was apprehended with firearms and ammunition and charged with various offenses. After being arraigned as a youthful offender, the juvenile was diagnosed with several information-processing disorders, including a language-based learning disorder. The juvenile was found incompetent to stand trial but capable of attaining competency in the future. However, after two competency proceedings, the juvenile was again found incompetent to stand trial, and the judge declined to make a definite finding on whether the juvenile could attain competency in the foreseeable future. The juvenile filed motions to dismiss the charges under the statute governing the dismissal of pending charges against incompetent persons, but these motions were denied.The Supreme Judicial Court of Massachusetts was tasked with deciding three main issues. First, whether the mental health code provides for the remediation of incompetent juveniles, particularly those incompetent but not mentally ill. Second, whether, in the absence of remediation programming under the mental health code, the ability to create and mandate remediation programming is within the scope of the Juvenile Court's inherent authority. Lastly, whether the pending charges against the juvenile can be dismissed "in the interest of justice."The court held that the mental health code does not provide for the remediation of juveniles found incompetent for reasons other than mental illness. It also rejected the argument that the ability to create and mandate remediation programming for incompetent juveniles falls within the purview of the Juvenile Court's inherent authority, stating that the creation of remediation programming falls within the purview of the Legislature. Regarding the dismissal of charges, the court remanded the matter to the Juvenile Court for further findings on whether the juvenile poses a present danger to the community. View "Makis M. v. Commonwealth" on Justia Law

The case involves a professional photographer who sexually exploited a minor. The defendant initially contacted the victim through a social networking site and began communicating with her through various means, eventually soliciting and receiving explicit images of the victim. The defendant also met the victim in person and sexually abused her. After the victim's parents reported the exploitation to the police, an investigation was launched. The police seized a computer tower, an external hard drive, and other items from the defendant's former residence. A forensic examination of the hard drives revealed explicit images of the victim, communications between the defendant and the victim, and hundreds of images of unidentified females in various stages of undress.The defendant was indicted on multiple counts, including aggravated rape of a child and enticement of a minor. He pleaded guilty to all charges, except for the eight counts of aggravated rape of a child, where he pleaded guilty to the lesser included offense of statutory rape. After being sentenced, the defendant filed a motion for the return of the seized property. The Commonwealth opposed the return of the property, arguing that it was in the "public interest" to destroy the devices. The Superior Court denied the defendant's request for the return of certain property.The Supreme Judicial Court of Massachusetts granted an application for direct appellate review. The court concluded that the procedural requirements set forth in G. L. c. 276, §§ 4 to 8, must be followed before a forfeiture decree may be issued under G. L. c. 276, § 3. The court vacated the Superior Court orders denying the return of certain property to the defendant and remanded the case for further proceedings consistent with its opinion. View "Commonwealth v. James" on Justia Law

The case involves a nonmarital child who was removed from the mother's custody due to neglect. The Department of Children and Families filed a care and protection petition in the Juvenile Court. The father, who had established paternity but had not sought custody prior to the filing of the petition, was granted temporary custody. The mother later waived her right to a hearing and stipulated that she was unfit, leading to the Juvenile Court judge awarding "permanent" custody to the father. However, the child filed a motion to dismiss the care and protection case, arguing that the Juvenile Court's custody order was sufficient to award permanent custody to the father.The Juvenile Court judge denied the child's motion, citing the statutory scheme which addresses the rights and responsibilities of the parents of nonmarital children. This scheme provides that the mother of a nonmarital child "shall" have custody "[i]n the absence of an order or judgment of a [P]robate and [F]amily [C]ourt [judge] relative to custody." The current practice in the Juvenile Court is to require the parent, who has been awarded permanent custody of the child in connection with a care and protection action, to seek an order of custody from the Probate and Family Court under the nonmarital child statutory scheme.The Supreme Judicial Court of Massachusetts affirmed the Juvenile Court judge's order denying the child's motion to dismiss the care and protection case. The court agreed that the current practice best reflects the Legislature's intent and harmonizes the two statutory schemes. The court also concluded that the practice complies with due process. View "Care and Protection of Jaylen" on Justia Law

In this case, the Supreme Judicial Court of Massachusetts was called upon to determine which law applied to the sealing of records from youthful offender proceedings - G. L. c. 276, § 100A, the adult criminal record sealing statute or G. L. c. 276, § 100B, the juvenile delinquency sealing statute. The case arose when the Commissioner of Probation denied the petitioner's request to have his youthful offender records sealed under § 100B and instead applied the adult criminal record sealing statute, § 100A.The court, after examining both statutes and considering the legislative intent, concluded that § 100B, the juvenile delinquency sealing statute, was the proper statute for the sealing of records of youthful offenders. The court found that the Legislature’s intent to aid, encourage, and guide juveniles, which includes youthful offenders, was more consistent with the process outlined in § 100B.The court held that it was an error for the Commissioner of Probation to refuse to seal the petitioner's Juvenile Court records under § 100B, as the petitioner had satisfied all the requirements under the statute. Therefore, the case was remanded back to the county court for the entry of a judgment in favor of the petitioner. View "In the Matter of an Impounded Case" on Justia Law

In this case, a Superior Court judge in Massachusetts sought guidance from the Supreme Judicial Court on three questions involving the pretrial confinement of a juvenile charged with murder. The juvenile, who was sixteen years old when he was charged with second-degree murder, was initially held without bail at a Department of Youth Services (DYS) facility due to a "courtesy" arrangement with the county sheriff. As the juvenile neared his eighteenth birthday, he was informed that he would be moved to an adult facility. In response, a Superior Court judge released him on personal recognizance on the murder charge and set bail on a related non-murder charge, ordering that he stay at the DYS facility.The Supreme Judicial Court of Massachusetts was asked to determine: 1) whether a Superior Court judge can commit a person under age eighteen charged with murder to DYS's care as a pre-trial detainee; 2) if not, can a Superior Court judge set bail on a charge related to, but other than murder, so that the person under eighteen is not held on bail on the murder charge and is committed to DYS's care; and 3) if the answers to questions 1 and 2 are "No," is the last paragraph of G. L. c. 119, § 68 (which mandates that juveniles charged with murder be committed to the custody of the sheriff) unconstitutional?The Supreme Judicial Court declined to answer the third question due to mootness, as the defendant had since turned eighteen and pleaded guilty to manslaughter. Regarding the first two questions, the court referred to its previous ruling in Nicholas-Taylor v. Commonwealth and affirmed that a Superior Court judge does not have the authority to commit a juvenile defendant charged with murder to the custody of DYS, nor can they sidestep this requirement by committing the juvenile to DYS on a related non-murder offense. Therefore, the answers to the first and second questions were "No." View "Commonwealth v. Padilla" on Justia Law

The Supreme Judicial Court affirmed the judgment of the juvenile court denying the Commonwealth's motion to revise Juvenile's sentence in this case, holding that a juvenile court judge may commit a youthful offender to the custody of the Department of Youth Services (DYS) until his twenty-first birthday and then suspend that commitment with conditions of probation.Pursuant to a plea agreement, the juvenile court judge adjudicated Juvenile to be a youthful offender. The judge ordered Juvenile committed to DYS until he reached the age of twenty-one and then suspended the commitment with conditions of probation until the day before Juvenile's twenty-first birthday. The Commonwealth moved for a revision of Juvenile's sentence, challenging the judge's decision to suspend Juvenile's commitment to DYS and to place him on probation, but the judge denied the motion. The Supreme Judicial Court affirmed, holding that the juvenile was within his discretion in suspending Juvenile's commitment pursuant to Mass. Gen. Laws ch. 276, 87. View "Commonwealth v. Dones" on Justia Law

The Supreme Judicial Court affirmed the judgment of the juvenile court adjudicating Appellant delinquent on two charges of attempting to burn a public building, holding that that Mass. Gen. Laws ch. 266, 5A, the attempted arson statute, is a specific intent crime.Appellant was arraigned in the juvenile court after he performed the TikTok "penny challenge" twice at his school, leading to his adjudication. On appeal, Appellant argued that section 5A requires proof of specific intent and that the evidence was insufficient to demonstrate that he acted with the specific intent to burn or set fire to the building. The Supreme Judicial Court affirmed, holding (1) attempt to burn a public building is a specific intent crime; and (2) the evidence demonstrated that Appellant specifically intended his conduct and its consequences. View "Commonwealth v. Qasim Q." on Justia Law

The Supreme Judicial Court vacated and set aside Appellant's conviction as a youthful offender and his adjudications of delinquency, holding that the trial judge erred in failing to conduct an inquiry into the jury foreperson's report of "discriminatory comments" being made during deliberations.Appellant, a juvenile, was found guilty for two firearm-related offenses. On appeal, Appellant argued that his right to a trial by a fair and impartial jury was twice violated at his trial. The court of appeals agreed, vacated the judgment and adjudications of delinquency, and set aside the verdicts. The Supreme Judicial Court affirmed, holding (1) the trial judge abused his discretion by not conducting a preliminary inquiry into the foreperson's report that the jury remained capable of impartially rendering a verdict; and (2) because it cannot be determined whether comments reflecting racial, ethnic, or other improper bias were made and, if so, whether they created a substantial risk of a miscarriage of justice, the case must be remanded for further proceedings. View "Commonwealth v. Ralph R." on Justia Law