Justia Massachusetts Supreme Court Opinion Summaries

Articles Posted in Massachusetts Supreme Court
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Jamie Melendez pleaded guilty to four counts of statutory rape of a child. As the result of Melendez's crimes, the victim gave birth to Melendez's biological child. The superior court ordered Melendez to acknowledge paternity, to financially support the child as conditions of his probation, and to abide by any orders of the probate and family court. The victim moved the superior court to revise the conditions of Melendez's probation, contending that his conditions of probation unlawfully bound her to an ongoing relationship with Melendez. The superior court denied the victim's motion, and a single justice of the Supreme Court denied the victim's petition for relief under Mass. Gen. Laws ch. 211, 3. The Supreme Court affirmed, where Melendez's sentence did not require the victim to be involved with Melendez in any way. View "H.T. v. Commonwealth" on Justia Law

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After a jury trial, Defendant was convicted of murder in the first degree, assault and battery by means of a dangerous weapon, and related firearm and ammunition offenses. The Supreme Court affirmed, holding (1) the joinder of the indictment charging assault and battery with the indictments charging murder in the first degree was proper and not unfairly prejudicial; (2) the trial judge did not abuse his discretion by asking members of the venire if they would be able fairly to evaluate the evidence notwithstanding the absence of physical evidence such as DNA or fingerprints linking Defendant to the crimes; (3) under the circumstances, the prosecutor did not improperly use the judge's voir dire questions to argue in closing that the jury should ignore the absence of scientific evidence; and (4) the trial court correctly denied Defendant's motion to suppress a box of ammunition seized from the kitchen of the apartment where he lived. View "Commonwealth v. Gray" on Justia Law

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John Rousseau and Michael Dreslinski (Defendants) were each convicted of four counts of arson, breaking and entering in the nighttime with intent to commit a felony, malicious destruction of property, and malicious injury to a railroad. On appeal, both Defendants argued that a warrant secured by the State police for the purpose of attaching a global positioning system (GPS) device to Dreslinski's vehicle, and then tracking its location over a thirty-one-day period, was not supported by probable cause and was overly broad. The Supreme Court affirmed Defendants' convictions but remanded Rousseau's case for modification of his probationary terms, holding (1) both Defendants had standing to challenge the GPS warrant; (2) probable cause supported the warrant; (3) the evidence was sufficient to prove Rousseau participated in the charged offenses; (4) the conditions of Rousseau's probation violated his constitutional right to access the courts by effectively denying him access to research and legal materials otherwise available to prison inmates; and (5) the trial judge did not commit prejudicial error in instructing the jury. View "Commonwealth v. Rousseau" on Justia Law

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Defendant turned himself in after killing his wife and stepson. Defendant made a long statement to police in his native Portuguese. An officer fluent in both Portuguese and English contemporaneously translated the statement. Following the trial court's denial of Defendant's motion to suppress the statement, the statement was introduced into evidence at Defendant's trial. A jury found Defendant guilty of two counts of murder in the first degree based on the theory of deliberate premeditation. The Supreme Court affirmed the convictions, holding (1) the trial court properly denied Defendant's motion to suppress, as (i) Defendant understood all of his Miranda rights before he made his statement to police, and (ii) Defendant both voluntarily waived his Miranda rights and voluntarily made his statement to police; (2) certain out-of-court statements were properly admitted under the state of mind exception to the rule against hearsay; (3) any misuse by the prosecutor of the out-of-court statements did not give rise to a substantial likelihood of a miscarriage of justice; and (4) the judge did not err in denying Defendant's request for a voluntary manslaughter instruction. View "Commonwealth v. Bins" on Justia Law

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In 1995, when he was fourteen years old, Plaintiff was adjudicated a delinquent child with respect to certain firearm charges. In 2010, Plaintiff applied for an unrestricted Class A license to carry firearms. The City of Boston denied the application, finding that Plaintiff had a disqualifying conviction. Plaintiff filed a complaint for judicial review, alleging, among other things, that he did not have any convictions or adjudications on his juvenile record that would disqualify him under Mass. Gen. Laws ch. 140, 131(d)(i) from obtaining a license. The municipal court dismissed the case, finding that Plaintiff was statutorily disqualified from possessing a license to carry a firearm due to his adjudication as a delinquent child for possession of a firearm without license. Plaintiff appealed, alleging that section 131(d)(i), as applied to his circumstances, violated his right to keep and bear arms under the U.S. Constitution. The Supreme Court held that the challenged statute did not infringe on Plaintiff's Second Amendment rights. Remanded. View "Chardin v. Police Comm'r of Boston" on Justia Law

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In 2001, Plaintiff, a special education student at a public elementary school in the town of Duxbury, fell and sustained injuries while unsupervised at school. Plaintiff presented a claim to the town based on her injuries. The Massachusetts Insurers Insolvency Fund, an association that settles unpaid claims covered by an insurance policy issued by an insurer that later becomes insolvent, made no offer to settle Plaintiff's claim despite its obligation to defend the town. Plaintiff subsequently commenced a consumer action against the insolvency fund. The superior court allowed the insolvency fund's motion for judgment on the pleadings. The Supreme Court decided that the insolvency fund was subject to consumer actions and remanded the case. The parties subsequently settled Plaintiff's negligence claim. A superior court judge ruled that Plaintiff was entitled to attorney's fees, a decision the insolvency fund appealed. The Supreme Court affirmed, holding that where, as here, a plaintiff prevails in a consumer action against the insolvency fund under the consumer protection act, the insolvency fund is liable for reasonable attorney's fees. View "Wheatley v. Mass. Insurers Insolvency Fund" on Justia Law

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Plaintiff, doing business as Spencer Brook Strings (SBS), rented string instruments to students in the Concord-Carlisle Regional School District. In 2011, the school district invited vendors of string instruments to bid to rent instruments to the parents of children in the school district and selected Music and Arts (M&A) as the winning bid. The school district then published on school Web sites a letter advising parents that M&A was the music rental company for Concord public schools. Plaintiff filed a complaint alleging that, by providing M&A with their "endorsement" and by failing to advertise SBS as a participating music rental company, Defendants had used their official positions to secure for M&A unwarranted privileges not available to similarly situated individuals in violation of Mass. Gen. Laws ch. 268A, 23(b)(2)(ii). The judge denied Plaintiff's motion for a preliminary injunction. The Supreme Court affirmed, holding (1) a finding of a violation of chapter 268A, 23(b)(2)(ii) by the State Ethics Commission after an adjudicatory proceeding and a request for rescission by the municipal agency were prerequisites to the filing of a complaint seeking rescission under Mass. Gen. Laws ch. 268A, 23(a); and (2) neither prerequisite was met in this case. View "Leder v. Superintendent of Schs." on Justia Law

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After a jury trial, Defendant was convicted on two indictments charging murder in the first degree on theories of deliberate premeditation, extreme atrocity or cruelty, and felony-murder. The jury also found Defendant guilty of several related offenses. The Supreme Court affirmed Defendant's convictions, holding (1) the trial court erred in admitting certain statements Defendant made to police, but the statements' admission did not result in a substantial likelihood of a miscarriage of justice; (2) the prosecutor's failure to timely disclose that a key witness had been unable to identify Defendant at voir dire violated Defendant's constitutional rights, but Defendant was not prejudiced by the delay; and (3) defense counsel was not ineffective for failing to move to suppress the admission of evidence obtained by Massachusetts police based on a pawn ticket that had been seized by New Jersey police after Defendant's arrest. View "Commonwealth v. Santana " on Justia Law

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After a jury trial, Defendants were convicted of murder in the first degree on a theory of extreme atrocity or cruelty, assault by means of a dangerous weapon, and related offenses for shootings that took place on a subway train. The Commonwealth's theory at trial was that the shootings had been committed as part of a joint venture. The Supreme Court affirmed, holding, inter alia, (1) there was sufficient evidence of joint venture; (2) the trial court did not prejudicially err in refusing to severe Defendants' trials; (3) the trial court correctly instructed the jury on joint venture and murder in the first degree on a theory of extreme atrocity of cruelty; (4) the prosecutor made an improper statement during closing arguments, but the improper remark did not make a difference in the jury's conclusions; and (5) the trial court did not abuse his discretion in admitting evidence of Defendants' gang affiliation. View "Commonwealth v. Akara" on Justia Law

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After a jury trial, Defendant was convicted of murder in the first degree on the theories of deliberate premeditation and extreme atrocity or cruelty and of larceny of a motor vehicle. The Supreme Court affirmed Defendant's convictions and declined to exercise its power to grant relief under Mass. Gen. Laws ch. 278, 33E with respect to the conviction of murder in the first degree, holding (1) the trial court did not err in partially denying Defendant's motion to suppress evidence seized during a search of Defendant's apartment; (2) the prosecutor did not include improper remarks in his opening statement; (3) the trial judge did not err in refusing to strike an answer by a Commonwealth witness concerning the meaning of "inconclusive" DNA test results; (4) the judge did not err in refusing to allow the Defendant's counsel to cross-examine a witness about specific acts of prior misconduct; (5) the prosecutor made an improper remark in closing arguments, but the remark was harmless; (6) evidence that the death was a homicide was properly introduced; and (7) because the evidence was sufficient to support the verdict, the trial court did not err by denying Defendant's motion for a required finding of not guilty. View "Commonwealth v. Almonte" on Justia Law