Justia Massachusetts Supreme Court Opinion Summaries
Ewing v. Davenport-Mello
The Supreme Judicial Court affirmed the judgment of a single justice of the court dismissing as moot Petitioner’s petition filed pursuant to Mass. Gen. Laws ch. 211, 3. Petitioner, an inmate, filed a complaint claiming that Respondents violated his civil rights by failing to provide him with a diabetic snack. A judge allowed Respondents’ motion to dismiss, and Petitioner filed a notice of appeal. Petitioner then filed this petition claiming that the trial court clerk’s office had not acted on his notice of appeal. The single justice dismissed the petition as moot because Petitioner’s notice of appeal had already been docketed in the trial court. The Supreme Judicial Court affirmed, holding that the single justice did not err in dismissing the Mass. Gen. Laws ch. 211, 3 petition as moot. View "Ewing v. Davenport-Mello" on Justia Law
Posted in:
Criminal Law, Government & Administrative Law
Commonwealth v. Vazquez
The Supreme Judicial Court affirmed Defendant’s conviction for murder in the first degree on a theory of deliberate premeditation and declined to exercise its extraordinary power under Mass. Gen. Laws ch. 278, 33E. On appeal, Defendant argued that his defense counsel, the trial judge, and the prosecutor all committed error, requiring a new trial. The Supreme Judicial Court held (1) any error on the part of the defense counsel did not create a substantial likelihood of a miscarriage of justice; (2) the admission of certain prior bad act evidence was error, but there was no substantial likelihood of a miscarriage of justice; (3) there was no error in the prosecutor’s remarks during closing argument; and (4) there was no error in the jury instructions. View "Commonwealth v. Vazquez" on Justia Law
Commonwealth v. Vazquez
The Supreme Judicial Court affirmed Defendant’s conviction for murder in the first degree on a theory of deliberate premeditation and declined to exercise its extraordinary power under Mass. Gen. Laws ch. 278, 33E. On appeal, Defendant argued that his defense counsel, the trial judge, and the prosecutor all committed error, requiring a new trial. The Supreme Judicial Court held (1) any error on the part of the defense counsel did not create a substantial likelihood of a miscarriage of justice; (2) the admission of certain prior bad act evidence was error, but there was no substantial likelihood of a miscarriage of justice; (3) there was no error in the prosecutor’s remarks during closing argument; and (4) there was no error in the jury instructions. View "Commonwealth v. Vazquez" on Justia Law
Peterson v. Commonwealth
The Supreme Judicial Court vacated the order denying the Commonwealth’s motion to dismiss the civil complaint filed by Plaintiff seeking compensation under the erroneous convictions statute, Mass. Gen. Laws ch. 258D. Plaintiff filed the complaint after the appeals court reversed his conviction for unlawful possession of a dangerous weapon. The superior court denied the Commonwealth’s motion to dismiss. The Supreme Judicial Court remanded the case to the superior court with directions to enter judgment for the Commonwealth, holding that Plaintiff’s conviction was not overturned on grounds tending to establish his innocence, thereby rendering him ineligible for compensation under the statute. View "Peterson v. Commonwealth" on Justia Law
Posted in:
Criminal Law, Personal Injury
Peterson v. Commonwealth
The Supreme Judicial Court vacated the order denying the Commonwealth’s motion to dismiss the civil complaint filed by Plaintiff seeking compensation under the erroneous convictions statute, Mass. Gen. Laws ch. 258D. Plaintiff filed the complaint after the appeals court reversed his conviction for unlawful possession of a dangerous weapon. The superior court denied the Commonwealth’s motion to dismiss. The Supreme Judicial Court remanded the case to the superior court with directions to enter judgment for the Commonwealth, holding that Plaintiff’s conviction was not overturned on grounds tending to establish his innocence, thereby rendering him ineligible for compensation under the statute. View "Peterson v. Commonwealth" on Justia Law
Posted in:
Criminal Law, Personal Injury
Commonwealth v. Morin
The Supreme Judicial Court vacated and set aside Defendant’s conviction for murder in the first degree on the theory of felony-murder, with unarmed robbery as the predicate felony, and remanded the matter to the superior court for further proceedings, holding that Defendant’s trial counsel provided constitutionally ineffective assistance. The Supreme Judicial Court held (1) the evidence was sufficient to support Defendant’s conviction; but (2) Defendant was entitled to a new trial because his trial counsel was deficient for failing to have filed a motion to suppress the search of Defendant’s cellular telephone, and the improperly-admitted evidence likely influenced the jury’s verdict. View "Commonwealth v. Morin" on Justia Law
Commonwealth v. Facella
The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of murder in the first degree on a theory of extreme atrocity and cruelty, denied Defendant’s motion for a new trial, and declined to exercise its power under Mass. Gen. Laws ch. 278, 33E to reduce the verdict or order a new trial. The court held (1) the trial judge did not err by admitting, in the Commonwealth’s case-in-chief, evidence of Defendant’s previous incarceration; (2) the trial judge did not err by giving limiting instructions regarding prior bad act evidence admitted in the Commonwealth’s case-in-chief or in its timing regarding the limiting instructions; (3) the trial judge did not abuse its discretion by admitting evidence of Defendant’s prior bad acts in the Commonwealth’s rebuttal case; and (4) nothing in the record warranted a reduced verdict or a new trial under section 33E. View "Commonwealth v. Facella" on Justia Law
Posted in:
Criminal Law
Commonwealth v. J.A.
The phrase “serious bodily harm” in the youthful offender statute, Mass. Gen. Laws ch. 119, 54 contemplates harm to human beings, not animals.A grand jury returned two youthful offender indictments against Juvenile, charging him with cruelty to animals and bestiality. The juvenile court allowed Juvenile’s motion to dismiss, ruling that the phrase “serious bodily harm” in the youthful offender statute refers only to human victims. The Supreme Judicial Court affirmed, holding that the “serious bodily harm” referenced in the statute does not apply to animals, and therefore, Juvenile’s conduct did not meet the requirements of the statute. View "Commonwealth v. J.A." on Justia Law
Posted in:
Criminal Law, Juvenile Law
Commonwealth v. Sullivan
The Supreme Judicial Court affirmed the judgment of the superior court convicting Defendant of felony murder, with the predicate felony of armed home invasion and declined to exercise its extraordinary authority to grant a new trial or to reduce the verdict to a lesser degree of guilt. The court held (1) the evidence was sufficient to support Defendant’s convictions; (2) there was no reversible error in the trial court’s evidentiary rulings concerning the introduction of testimony about DNA found on objects at the crime scene and testimony concerning the use of a DNA profile of the defendant stored in a national database; and (3) the motion judge did not reversibly err in denying Defendant’s motion for a new trial on the ground that the Commonwealth did not provide exculpatory evidence concerning a forensic scientist’s failure to pass required proficiency tests. View "Commonwealth v. Sullivan" on Justia Law
Posted in:
Criminal Law
Brangan v. Commonwealth
The Supreme Judicial Court affirmed the decision of a single justice of the county court denying Petitioner’s petition for relief from the trial judge’s denial of his motion to dismiss the indictment against him for armed robbery while masked after the Commonwealth’s closing argument led to a mistrial. Specifically, Petitioner argued that the principles of double jeopardy barred his retrial because (1) the Commonwealth did not present sufficient evidence to support a guilty finding; or (2) alternatively, the prosecutor’s misconduct warranted a dismissal of the indictment. The Supreme Judicial Court disagreed, holding (1) there was sufficient evidence for a rational trier of fact to conclude beyond a reasonable doubt that the Commonwealth proved each element of the crime; and (2) none of the evidence presented by Petitioner rose to the level of proving that the prosecutor engaged in “intentional” misconduct by knowingly making a false statement to the jury. View "Brangan v. Commonwealth" on Justia Law
Posted in:
Criminal Law