Justia Massachusetts Supreme Court Opinion Summaries

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

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

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

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

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

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

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

At issue was the Zoning Board of Appeals’ (ZBA) denial of Plaintiff’s application for a comprehensive permit to develop a mixed-income project. Plaintiff owned parcel of land in an area zoned for limited manufacturing use. The site was subject to a restrictive covenant owned by the city of Newton, and the city owned an abutting parcel with a deed restriction requiring that it be used only for conservation, parkland, or recreational use. Plaintiff sought to amend the deed restriction to allow a residential use at the site and to permit construction in the nonbuild zone. The ZBA denied Plaintiff’s permit application, concluding that it lacked authority to amend the deed restriction, an interest in land held by the city. The Department of Housing and Community Development (HAC) affirmed. Plaintiff sought judicial review. A land court judge granted Defendants’ motions for judgment on the pleadings, concluding that the HAC does not have authority to order the city to relinquish its property interest. The Supreme Judicial Court affirmed, holding (1) the negative easement is a property interest in land, and the ZBA does not have authority modify certain types of property interests in land; and (2) the restrictive covenant is not invalid where the restrictions provide valuable interests to the city. View "135 Wells Avenue, LLC v. Housing Appeals Committee" on Justia Law

The Supreme Judicial Court affirmed the judgment of the county court denying, without a hearing, a juvenile’s petition for relief under Mass. Gen. Laws ch. 211, 3.The juvenile was charged with making a bomb threat. A judge in the juvenile court arraigned the juvenile under the belief that she lacked authority to consider a motion to dismiss the complaint prior to arraignment. Upon reconsideration, the judge determined that she did have authority to dismiss before arraignment, vacated the arraignment of the juvenile, and directed the probation department to expunge the juvenile court’s activity record information. Thereafter, the judge again reversed herself, reinstated the juvenile’s arraignment and vacated the expungement order. The juvenile sought relief from this interlocutory ruling pursuant to this Mass. Gen. Laws ch. 211, 3 petition. The Supreme Court affirmed, holding that the circumstances of this case did not entitle the juvenile as a matter of right to invoke the court’s extraordinary power under Mass. Gen. Laws ch. 211, 3. View "Benjamin B. v. Commonwealth" on Justia Law

One year ago, in Deal v. Commissioner of Correction, 475 Mass. 307 (2016) (Deal I), the Supreme Judicial Court concluded that the procedure used by the Department of Correction to determine the security classification of juvenile homicide offenders violated Mass. Gen. Laws ch. 119, 72B, as amended by St. 2014 ch. 189, 2, which prohibits the Department from categorically barring juvenile homicide offenders from being placed in minimum security facilities. Since then, the Department has developed a modified process for classifying juvenile homicide offenders. Petitioners - juvenile homicide offenders who were also petitioners in Deal I - challenged that modified process in this case. The Supreme Court held that, after applying the holding in Deal I, the Department continued to fall short of the requirements of section 72B where the Department’s written explanations for blocking the majority of objectively qualifying juvenile homicide offenders from placement in a minimum security facility do not go far enough to ensure that the classification procedure is actually individualized and that no juvenile homicide offender is categorically barred from classification to a minimum security facility. View "Deal v. Commissioner of Correction" on Justia Law