Justia Massachusetts Supreme Court Opinion Summaries

Defendant was convicted of murder in the second degree and received a mandatory sentence of life imprisonment with eligibility for parole after fifteen years. Defendant was fifteen years old at the time of the offense. Defendant appealed, arguing, among other things, that his mandatory life sentence constituted cruel and unusual punishment in violation of the Eighth Amendment to the U.S. Constitution and article 26 of the Massachusetts Declaration of Rights. The Supreme Judicial Court affirmed, holding (1) a mandatory life sentence with eligibility for parole after fifteen years for a juvenile homicide offender convicted of murder in the second degree does not offend the Eighth Amendment or article 26 or other constitutional rights; and (2) Defendant’s challenges to his underlying conviction were without merit. View "Commonwealth v. Okoro" on Justia Law

In 2013, Gregory Diatchenko filed the present action seeking a declaration that, because he was seventeen at the time he committed the offense leading to his conviction of murder in the first degree, his mandatory sentence of life without parole was unconstitutional. Following Miller v. Alabama, the Supreme Judicial Court determined that the mandatory imposition of such a sentence was unconstitutional. The Court held that a juvenile homicide offender who receives a mandatory sentence of life imprisonment must be afforded the opportunity for release on parole. Diatchenko and another petitioner, both of whom became immediately eligible for parole pursuant to the Court’s decision in Diatchenko I, contended that, to ensure their opportunity for release through parole was meaningful, they must have access to counsel, access to funds for counsel and for expert witnesses, and an opportunity for judicial review of the decision on their parole applications. The Supreme Judicial Court agreed with the petitioners, holding (1) the procedural protections of representation by counsel and the opportunity to obtain expert assistance in connection with that initial parole hearing are necessary for juvenile homicide offenders serving a mandatory life sentence; and (2) such offenders are entitled to limited judicial review of a parole board decision denying initial parole. View "Diatchenko v. District Attorney" on Justia Law

At a hearing before a Juvenile Court judge, a juvenile admitted to sufficient facts with respect to two counts of indecent assault and battery on a person fourteen or older. The juvenile subsequently filed a motion seeking relief from the obligation to register as a sex offender. A judge denied the juvenile’s motion for relief from registration, determining that the juvenile posed a risk of reoffense and would be required to register with the Sex Offender Registry Board. The Supreme Court affirmed, holding that the judge’s ultimate determination that the juvenile should not be relieved of the obligation to register as a sex offender did not constitute an abuse of her discretion. View "L.L. v. Commonwealth" on Justia Law

Petitioners Ronald Watts and Kevin Aguirre were charged by way of complaints issued in district court with criminal offenses that Petitioners allegedly committed when they were each seventeen years old. The Governor subsequently signed St. 2013 ch. 84 (Act), which extended the juvenile court’s jurisdiction to persons who were seventeen years old at the time of committing an offense. Petitioners moved to dismiss the district court charges against them pursuant to the Act, claiming that the district courts lacked jurisdiction over them because they were seventeen at the time the alleged offenses occurred and when the criminal proceedings had begun. The Supreme Judicial Court denied Petitioners’ motions, holding that the Act does not apply retroactively to cases involving juveniles who were seventeen years of age at the time of the alleged offense and whose criminal cases in the superior court or district court were begun prior to, and were pending on, the effective date of the Act.View "Watts v. Commonwealth" on Justia Law

When Muniur M. was fourteen years old, he was charged with delinquency by reason of rape of a child with force. Muniur later admitted to sufficient facts to warrant an adjudication of delinquency on the charge of statutory rape. The juvenile court judge adjudicated Muniur delinquent and committed him to the Department of Youth Services but suspended the commitment and placed him on probation. Over eighteen years later, Muniur filed a motion to vacate his admission and for a new trial, alleging that his father forced him to admit to sufficient facts. After a nonevidentiary hearing, the district court judge allowed the motion. The Supreme Court vacated the judge’s order and remanded the matter for an evidentiary hearing, holding that the judge erred by not allowing evidence to be taken, and tested by cross-examination, on the substantial issue of the voluntariness of Muniur’s admission. View "Commonwealth v. Muniur M." on Justia Law

Defendant committed murder when he was seventeen years old. Defendant was subsequently convicted in the superior court of murder in the first degree and related weapons charges. While Brown was awaiting trial, the U.S. Supreme Court decided Miller v. Alabama, which held that mandatory life-without-parole sentences for juvenile homicide offenders violate the Eighth Amendment. The statutory sentencing scheme in Massachusetts requires, however, that all defendants over the age of fourteen who are convicted of murder in the first degree must be sentenced to life without the possibility of parole. Consequently, Defendant's sentencing was stayed until the Maine Supreme Court could render an opinion regarding the issue. The Supreme Court concluded that Defendant was entitled to the benefit of Miller and Commonwealth v. Diatchenko, in which the Court held that all life-without-parole sentences for juvenile offenders violate the Massachusetts Declaration of Rights. Consequently, the Court held that Defendant may not be sentenced to life without parole. Remanded for sentencing. View "Commonwealth v. Brown" on Justia Law

The Commonwealth filed five delinquency complaints against Defendant when he was seventeen years old based on the alleged sexual abuse of a victim. Defendant was summonsed into court on the complaints while he was still seventeen, but Defendant had turned eighteen by the time of his first scheduled court appearance and arraignment. The Commonwealth subsequently obtained youthful offender indictments against Defendant based on the portion of the alleged abuse that took place when Defendant was between fourteen and seventeen years old. The juvenile court subsequently reported to the Supreme Court questions concerning issues of the juvenile court's jurisdiction. The Supreme Court held (1) the term "apprehended" in Mass. Gen. Laws ch. 119, 72 is marked by the commencement of process, typically through a summons, provided the individual is able to the court at that time; (2) an individual may not be indicted as a youthful offender after he has turned eighteen for offenses he allegedly committed between the ages of fourteen and seventeen; and (3) a youthful offender indictment may not issue against an individual after his eighteenth birthday, regardless of whether a delinquency complaint on the same facts has been filed before the individual's eighteenth birthday. View "Commonwealth v. Mogelinski" on Justia Law

A delinquency complaint charged Juvenile with one count of possession of a class D substance (marijuana) with intent to distribute. Juvenile filed a motion to dismiss, arguing that the complaint was not supported by probable cause that he intended to distribute the marijuana found in his possession. The juvenile court judge allowed the motion but concluded that he was obliged to arraign Juvenile before dismissing the complaint. The Supreme Court affirmed, holding (1) the information in the complaint fell short of probable cause to believe Juvenile intended to distribute the marijuana in his possession; and (2) a juvenile court judge may allow a motion to dismiss before the arraignment of a juvenile where the judge concludes that prearraignment dismissal is in the best interests of the child and the interests of justice. View "Commonwealth v. Humberto H." on Justia Law

Juvenile was arraigned in the juvenile court on a complaint alleging indecent assault and battery on a person under the age of fourteen. Juvenile pleaded delinquent and was placed on supervised probation for a period of six months. Although Juvenile was not advised during the plea colloquy that GPS monitoring would be required as a condition of probation, the judge entered an order requiring Juvenile to wear a GPS monitoring device during the term of his probation. The judge denied Juvenile's motion for relief from GPS monitoring. The Supreme Court dismissed Juvenile's appeal, holding that a juvenile court retains the discretion, based on the totality of the circumstances, to determine whether GPS monitoring should be imposed as a condition of probation for a juvenile who is adjudicated delinquent after committing a sex offense. View "Commonwealth v. Hanson H." on Justia Law

In 1995, Defendant was charged with assault and battery by means of a dangerous weapon and indecent assault and battery on a child under the age of fourteen. At the time, Defendant was a minor and primarily spoke Khmai. During his plea colloquy, Defendant admitted to sufficient facts and was placed on probation. Defendant was committed to the Department of Youth Services after he violated the terms of his probation. In 2009, as an adult, Defendant sought to vacate his pleas, asserting he did not knowingly and voluntarily admit to sufficient facts where no interpreter was present during his plea colloquy and where he was denied effective assistance of counsel. The juvenile court denied Defendant's motion for a new trial, and the appeals court affirmed. The Supreme Court affirmed, holding that Defendant did not provide sufficient evidence to rebut the presumption of regularity of his plea proceedings and did not demonstrate he was denied the effective assistance of counsel. View "Commonwealth v. Yardley Y." on Justia Law