Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court held that, in light of Miller v. Alabama, 567 U.S. 460 (2012), juvenile delinquency adjudications for violent offenses may serve as predicate offenses for adults under the Armed Career Criminal Act (ACCA), Mass. Gen. Laws ch. 269, 10G.Defendant was indicted at age eighteen for unlawful possession of a firearm. Defendant had twice between adjudicated delinquent for crimes of violence, and therefore, the Commonwealth charged Defendant with violating the ACCA. While the case was proceeding, a superior court judge sua sponte raised the issue of whether it was a violation of due process to use juvenile adjudications to enhance sentencing in the same manner as adult convictions. The Supreme Judicial Court allowed Defendant’s application for direct appellate review and held that qualifying juvenile adjudications may be used as a predicate offense for enhanced penalties under Mass. Gen. Laws ch. 269, 10G. View "Commonwealth v. Baez" on Justia Law

The Supreme Judicial Court vacated Defendant’s convictions, holding that the prosecutor’s closing argument telling the jury of critical corroborative evidence that was not presented at trial was prejudicial error.After a jury trial, Defendant was found guilty of three counts of rape of a child and one count of indecent assault and battery upon a child. Defendant appealed, asserting three claims of error. The Supreme Judicial Court remanded the case to the superior court for a new trial based on the prosecutor’s improper closing argument, which the Court held could have influenced the jury to convict. The Court then addressed Defendant’s other two claims of error by holding (1) the trial judge did not abuse his discretion in admitting the expert testimony of the treating physician of the victim, and (2) the judge did not unfairly limit the jury’s consideration of the Bowden defense by instructing the jury to decide the case based solely on the evidence. View "Commonwealth v. Alvarez" on Justia Law

At issue was whether Steward Carney Hospital owed Mary Miller, who was fatally stabbed in her home by N, a former patient of the hospital, and her family a duty of care, and if so, whether the hospital breached that duty when one of its physicians released N from involuntary psychiatric commitment.Plaintiffs, a representative of Miller’s estate and the mother of Miller’s granddaughter, brought this tort action against the hospital. A superior court judge allowed Defendants’ motion for summary judgment, concluding that the hospital did not owe Plaintiffs any duty of care. The Supreme Judicial Court affirmed, holding that the hospital did not owe the victim or her family any duty of care at the time of the killing because the order of civil commitment to hold N did not impose an independent duty on the hospital for N’s treatment and did not require the hospital to exercise any medical judgment as to the appropriateness of N’s release. View "Williams v. Steward Health Care System, LLC" on Justia Law

The Supreme Judicial Court affirmed the judgment of a single justice denying Juvenile’s petition filed pursuant to Mass. Gen. Laws ch. 211, 3 challenging the superior court judge’s denial of Juvenile’s petition for bail review, holding that the single justice did not err or abuse his discretion in denying Juvenile’s petition seeking review of the bail determination.Juvenile was charged in a delinquency complaint with being an accessory to murder after the fact and assault and battery by means of a dangerous weapon. A juvenile court judge set bail at $50,000. Juvenile petitioned for a review of the bail determination. The superior court judge denied the petition. The Supreme Judicial Court affirmed, holding (1) the bail determination was appropriately made, and there was no violation of Juvenile’s rights; and (2) therefore, the single justice did not err in denying Juvenile’s Mass. Gen. Laws ch. 211, 3 petition. View "Juvenile v. Commonwealth" on Justia Law

At issue in this medical malpractice action was whether a surety bond in the amount of $6,000 satisfied the requirement of Mass. Gen. Laws ch. 231, 60B that a plaintiff wishing to proceed after a tribunal has found in favor of a defendant must file “bond in the amount of [$6,000] in the aggregate secured by cash or its equivalent.”A medical malpractice tribunal concluded that there was not evidence sufficient to raise a legitimate question of liability appropriate for judicial inquiry, as required by section 60B. Plaintiff then filed a surety bond in the amount of $6,000 in order to pursue his claim through the judicial process. A superior court judge allowed a defendant’s motion to strike the surety bond and to dismiss the complaint, concluding that the surety bond did not satisfy Plaintiff’s statutory obligation. The Supreme Judicial Court affirmed, holding that a surety bond in the face amount of $6,000 is not the “equivalent” of $6,000 in cash for purposes of Mass. Gen. Laws ch. 231, 60B. View "Polanco v. Sandor" on Justia Law

The Supreme Judicial Court affirmed Defendant’s conviction for murder in the first degree on a theory of extreme atrocity or cruelty and declined to exercise its authority to grant relief under Mass. Gen. Laws ch. 278, 33E, holding that Defendant’s argument that he was entitled to a new trial for several reasons was unavailing.Specifically, the Court held (1) Defendant was not deprived of the right to present a defense based on the judge’s exclusion of an out-of-court statement to police made by the only eyewitness to the altercation a few hours after the fight; (2) the trial judge did not abuse her discretion in excluding so-called Adjutant evidence, including an unavailable witness’s recorded statement to police and other evidence of the victim’s violent conduct; and (3) Defendant’s right to a fair trial was not violated by the trial judge’s failure sua sponte to conduct a recusal analysis. View "Commonwealth v. Deconinck" on Justia Law

The Supreme Judicial Court affirmed Defendant’s conviction of murder in the first degree and declined to exercise its extraordinary power to set aside or reduce the verdict under Mass. Gen. Laws ch. 278, 33E, holding that Defendant’s claims of ineffective assistance of counsel failed and that the trial judge did not commit reversible error in her rulings.Specifically, the Court held (1) the trial judge did not err in admitting portions of a recorded police interview; (2) the trial judge properly admitted testimony regarding an argument a witness had with the victim; (3) the judge did not err in disallowing defense counsel’s line of questioning to a witness; and (4) Defendant did not receive ineffective assistance of trial counsel during the proceedings below. View "Commonwealth v. Cruzado" on Justia Law

The Supreme Judicial Court held that a conditional guilty plea is permissible if it is entered with the consent of the superior court and the Commonwealth and identifies the specific ruling from which the defendant intends to appeal.After noting that Mass. R. Crim. P. 12 does not specifically authorize a conditional guilty plea, and nothing in the language of Rule 12 or its amendments contemplates this approach, and neither the Rule nor any statute prohibits a conditional guilty plea, the Supreme Judicial Court, in exercise of its superintendence power, responded to a reported question from a superior court judge on the issue. The Court decided that a conditional guilty plea is permissible so long as it is entered with the consent of the court and the Commonwealth, and the defendant specifies the pretrial motion from which he seeks to appeal at the time the plea is entered. The Court asked the standing advisory committee on the rules of criminal procedure to propose a suitable amendment to Rule 12 to delineate the requirements for conditional guilty pleas. View "Commonwealth v. Gomez" on Justia Law

The Supreme Judicial Court affirmed the motion judge’s denial of Defendant’s motion seeking a new trial on the basis that he was the target of a grand jury investigation and that his grand jury testimony was improperly admitted under Commonwealth v. Woods, 466 Mass. 707 (2014) (Woods I), holding that the motion judge did not err.In Woods I, the Supreme Judicial Court upheld the trial judge's finding that Defendant was not a target of the grand jury when he was called before the grand jury to testify. The Court further announced a prospective rule requiring that grand jury witnesses who are targets of a criminal investigation be given self-incrimination warnings before testifying. Following Woods I, Defendant filed a motion for a new trial arguing that new facts established that he was a target of a grand jury investigation. The motion judge concluded that Defendant was a target of the investigation but that the decision in Woods I upholding the admission of Defendant’s grand jury testimony did not depend on the factual finding that Defendant was not a target of the investigation. The Supreme Judicial Court affirmed the denial of Defendant’s motion for a new trial, holding that, irrespective of Defendant’s target status, he was not entitled to the new rule. View "Commonwealth v. Woods" on Justia Law

The Supreme Judicial Court held that Phone Recovery Services, LLC (PRS), as a corporation, did not have standing to bring this qui tam action on behalf of the Commonwealth against Defendants, Verizon of New England, Inc. and other communication services providers, under the Massachusetts False Claims Act, Mass. Gen. Laws ch. 12, 5A-50.In its complaint, PRS claimed that Defendants failed to collect from their customers and remit to the Commonwealth the statutorily required surcharge for 911 emergency telephone service and knowingly provided false information to the Commonwealth to avoid certain financial obligations. The superior court allowed Defendants’ motion to dismiss, concluding that the 911 surcharge was not subject to the Act. The Supreme Judicial Court remanded the matter for a judgment dismissing the case for lack of subject matter jurisdiction, holding that PRS had no standing to bring this action because it was not an “individual” for purposes of Mass. Gen. Laws ch. 12, 5A and thus did not qualify as a relator under the Act. View "Phone Recovery Services, LLC v. Verizon of New England, Inc." on Justia Law