Justia Massachusetts Supreme Court Opinion Summaries

Defendant, who was a juvenile at the time of the offense, was indicted for murder in the second degree. The superior court judge dismissed the indictment on the ground that the Commonwealth presented insufficient evidence to the grand jury to support an indictment of murder in the second degree. A majority of the Supreme Court affirmed the order dismissing the indictment, holding (1) contrary to the superior court judge's ruling, the evidence before the grand jury supported the indictment for murder in the second degree; but (2) the grand jury should have been, but was not, instructed by the prosecutor on the elements of murder and on the legal significance of the mitigating circumstances raised by the evidence. View "Commonwealth v. Walczak" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on a theory of deliberate premeditation. The Supreme Court affirmed the convictions, holding (1) the trial judge did not err in instructing the jury; (2) it was not improper for a judge other than the trial judge to provide the jury with a supplemental instruction where the trial judge was neither sick nor disabled, and where the substitute judge did not certify in writing that he had familiarized himself with the record of the trial; (3) Defendant received effective assistance of counsel, and even if counsel made the mistakes claimed on appeal, counsel's performance did not create a substantial likelihood of a miscarriage of justice; and (4) Defendant received a fair trial, and the interests of justice did not require the reduction of the murder conviction to a lesser degree of guilt or a new trial. View "Commonwealth v. Taylor" on Justia Law

Defendant was charged in a two-count complaint with distribution of a class B substance and a drug violation near a school or park. Defendant moved to suppress evidence obtained from a warrantless search of his cellular telephone, which had been seized from him after his arrest and at the time of booking, arguing that the telephone was searched without probable cause or his consent in violation of the Fourth and Fourteenth Amendments. The municipal court denied the motion after an evidentiary hearing. The Supreme Court affirmed the denial of Defendant's motion to suppress evidence, holding that the limited search of Defendant's cellular telephone to examine the recent call list was a permissible search incident to Defendant's lawful arrest. View "Commonwealth v. Phifer " on Justia Law

This case concerned a limited search of the recent call list displayed on a cellular telephone that had been seized by the police in a warrantless search of Defendant incident to arrest. A judge in the municipal court allowed Defendant's motion to suppress evidence of this cellular telephone search, ruling that it had taken place at a location and time spatially and temporally separated from the arrest and therefore was not a valid search incident to arrest. The Supreme Court reversed the partial allowance of Defendant's motion to suppress, holding, as it did in Commonwealth v. Phifer, that in the particular circumstances presented, the very limited search of the cellular telephone was permissible. View "Commonwealth v. Berry" on Justia Law

Petitioner filed a petition in the county court seeking an investigation into alleged misconduct of an assistant clerk of the court and a determination that he violated his obligation under the Code of Professional Responsibility for Clerks of the Courts. A single justice ordered that the petition be dismissed on the ground that there is no right to bring a private action in court to obtain discipline of a clerk. The Supreme Court affirmed, holding that although a private individual may file a complaint with the Board of Bar Overseers or the Committee on Professional Responsibility for Clerks of the Courts, there is no private right to operate the disciplinary process. View "Gorbatova v. First Assistant Clerk of the Supreme Judicial Court" on Justia Law

Defendant was convicted of murder in the first degree based on deliberate premeditation. Defendant filed a motion for a new trial alleging that his trial counsel was ineffective. The motion was denied. Defendant's direct appeal and the appeal from the denial of his motion for a new trial were consolidated in the Supreme Court. The Supreme Court affirmed the conviction and the denial of the motion for a new trial, holding that there was no error or abuse of discretion in the denial of Defendant's motion for a new trial, as trial counsel was not ineffective for failing to (1) object to the admission of gang-related evidence; (2) object to the testimony of a substitute medical examiner; (3) present evidence of Defendant's state of intoxication; and (4) request manslaughter instructions. View "Commonwealth v. Leng" on Justia Law

Plaintiff, an inmate at a correctional center, was held in administrative segregation in center's special management unit (SMU) on awaiting action status as prison officials sought his transfer or reclassification. During that time, Plaintiff's detainment was given the informal review provided by the Department of Correction (DOC) regulations that govern detention of inmates in an SMU. Claiming that he was entitled the review procedures provided by regulation to inmates housed in a departmental segregation unit, Plaintiff brought suit alleging violations of his constitutional due process rights and of various state statutes and regulations, and seeking declaratory and injunctive relief as well as money damages. The superior court granted Plaintiff's partial motion for summary judgment, ruling that Defendants had violated his right to due process. The judge denied Defendants' cross motion for summary judgment insofar as it sought to dismiss Plaintiff's claims as barred under the doctrine of qualified immunity for public officials. The Supreme Court held (1) Plaintiff's administrative segregation was unlawful, but (2) the law in this regard was not clearly established at the time of the underlying events, and with respect to Plaintiff's claim for damages, Defendants were entitled to summary judgment on the basis of qualified immunity. View "LaChance v. Comm'r of Corr." on Justia Law

Plaintiff Creative Playthings Ltd., a Massachusetts corporation, entered into a franchising agreement with Defendant under which Defendant agreed to operate a Creative Playthings franchise store in Florida. Plaintiff later terminated its agreement with Defendant and commenced this action against Defendant in the U.S. district court for breach of contract and associated claims. Defendant filed several counterclaims against Creative. Creative moved for summary judgment on Defendant's counterclaims, asserting they were time barred under the limitations provision in the franchise agreement. The federal district court judge declined to decide Creative's motion and instead certified the question of whether contractually shortened statutes of limitations are generally enforceable under Massachusetts law. The Supreme Court answered by holding that, in a franchise agreement governed by Massachusetts law, a limitations period in the contract shortening the time within which claims must be brought is valid and enforceable under Massachusetts law if the claim arises under the contract and the agreed-upon limitations period is subject to negotiation by the parties, is not otherwise limited by controlling statute, is reasonable, is not a statute of repose, and is not contrary to public policy. View "Creative Playthings Franchising Corp. v. Reiser" on Justia Law

Defendant was indicted for possession with intent to distribute heroin and for possession with intent to distribute heroin, subsequent offense. The charges resulted from the execution of a search warrant at Defendant's home. The affidavit submitted in support of the search warrant application stated that the police had conducted four controlled drug purchases from Defendant and referred to five different confidential informants. Defendant filed a motion for disclosure of the identity of one of the informants, stating she believed the informant was John Smith and that she intended to raise an entrapment defense at trial. The judge who acted on the motion ordered that the Commonwealth confirm or deny whether the informant was Smith. The Commonwealth filed a petition seeking relief from the order, which a single justice denied. The Supreme Court affirmed and ordered the Commonwealth to comply with the order forthwith. View "Commonwealth v. Elias" on Justia Law

Defendant was classified by the sex offender registry board as a level two sex offender. Defendant subsequently registered with the police department. When Defendant failed to register again a few months later during the month of his birth, he was charged with a single count of failing to register as a sex offender in violation of Mass. Gen. Laws ch. 6, 178F 1/2. Defendant pled guilty to the offense and later filed a motion to withdraw the guilty plea. His motion was denied. The Supreme Court reversed, holding (1) although Defendant admitted during the plea hearing that he did not register in his birth month, the statute did not require him to do so; and (2) being under no obligation to register in his birth month, Defendant could not be convicted of the offense of failure to register. View "Commonwealth v. Loring" on Justia Law