Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed Defendant’s convictions for the first-degree murders of three victims and concluded that Defendant was not entitled to relief under Mass. Gen. Laws ch. 278, 33E. The court held (1) the evidence was sufficient to support Defendant’s convictions; (2) the trial judge did not abuse his discretion in admitting photographs of items found during the search of Defendant’s apartments; (3) the judge did not abuse his discretion in admitting Defendant’s statement regarding scars on his right arm; (4) there was not a substantial likelihood of a miscarriage of justice in the prosecutor’s closing argument; and (5) the verdicts of murder in the first degree are fully consonant with justice. View "Commonwealth v. Veiovis" on Justia Law

A patient who qualifies for the medical use of marijuana and has been terminated from her employment because she tested positive for marijuana as a result of her lawful medical use of marijuana may seek a civil remedy against her employer through claims of handicap discrimination in violation of Mass. Gen. Laws ch. 151B. The Supreme Judicial Court thus reversed the dismissal of Plaintiff’s claim for handicap discrimination and related claims under chapter 151B but affirmed the allowance of the motion to dismiss as to the counts claiming an implied private cause of action under the medical marijuana act and wrongful termination in violation of public policy, holding that there is no implied statutory private cause of action under the medical marijuana act and that Plaintiff failed to state a claim for wrongful termination in violation of public policy. View "Barbuto v. Advantage Sales & Marketing, LLC" on Justia Law

The Supreme Judicial Court affirmed Defendant’s convictions for murder in the first degree on a theory of felony-murder, as well as unlawful possession of a firearm and willful interference with a criminal investigation, and the judge’s order denying Defendant’s motion for a new trial. The court also declined to reduce or set aside Defendant’s murder conviction under Mass. Gen. Laws ch. 278, 33E. The court held (1) the judge did not err in denying Defendant’s motion for a required finding of not guilty of murder int the first degree and unlawful possession of a firearm; and (2) under the circumstances of this case, the judge did not err in denying Defendant’s motion for a new trial based on the Commonwealth’s failure to disclose allegedly exculpatory evidence. View "Commonwealth v. Cooley" on Justia Law

It was not appropriate to vacate the arbitration award in this case concerning the termination of a police officer.The City of Boston terminated David Williams, a Boston police officer, for using a choke hold in arrested an unarmed suspect for disorderly conduct and making false statements in a departmental investigation. An arbitrator found no underlying misconduct on the part of the officer and ruled that the City of Boston lacked just cause to terminate the officer and ordered his reinstatement. The City filed a complaint seeking to vacate the arbitrator’s award. The superior court dismissed the complaint. The Supreme Judicial Court affirmed, holding that it was not appropriate to vacate the arbitration award where the award neither exceeded the arbitrator’s authority nor violated public policy and where no underlying misconduct was found. View "City of Boston v. Boston Police Patrolmen's Association" on Justia Law

During an armed home invasion at a Dudley apartment, Muller and an accomplice, who subsequently pleaded guilty, shot and killed two occupants and critically wounded a third. Muller was convicted of two counts of murder in the first degree, on the theories of deliberate premeditation and felony-murder, armed assault with intent to murder, armed home invasion and unlawful possession of a firearm. At trial, Muller admitted that he had shot the victims; his primary defense was that he lacked criminal responsibility because of mental illness and cocaine addiction. The Massachusetts Supreme Judicial Court affirmed. While the jury instructions were erroneous in failing to clarify that the voluntary consumption of drugs or alcohol does not preclude the defense of lack of criminal responsibility where the mental disease or defect, standing alone, causes the defendant to lose the substantial capacity to appreciate the wrongfulness of his conduct or to conform his conduct to the requirements of the law, the error did not create a substantial likelihood of a miscarriage of justice. Although the instruction regarding the inference of sanity was error, the judge ameliorated the error where he specifically instructed the jury that they did not have to draw such an inference, especially in light of the jury's view of the expert medical testimony. View "Commonwealth v. Muller" on Justia Law

Double jeopardy principles did not preclude the Commonwealth from retrying Defendant on a complaint charging a violation of Mass. Gen. Laws ch. 90, 24(1)(a)(1) on the theory of operation of a motor vehicle with a percentage of alcohol in his blood of .08 or greater (per se violation) after a jury acquitted Defendant on the theory of operation of a motor vehicle while under the influence of intoxicating liquor (impaired ability violation). The Commonwealth prosecuted the case on both theories, and the jury reached a verdict on the impaired ability violation only. After a new complaint issued charging a per se violation of chapter 90, section 24(1)(a)(1), Defendant moved to dismiss the complaint as a violation of his double jeopardy rights.The judge denied the motion. The Supreme court affirmed, holding that retrial was constitutionally permitted where the Commonwealth prosecuted the case on both theories and the jury reached a verdict on only one of those theories. View "Commonwealth v. Hebb" on Justia Law

The Supreme Judicial Court reversed the denial of Defendant’s motion to suppress evidence recovered pursuant to a search warrant, holding that the search warrant lacked probable cause.Defendant was indicted on various charges in connection with the possession of an unlicensed firearm. Two of those charges included sentence enhancement as an armed career criminal. Defendant filed a motion to suppress evidence recovered from a safe pursuant to a search warrant and also moved to dismiss the sentence enhancements. Both motions were denied. The Supreme Judicial Court reversed the denial of both motions and remanded the matters to the county court, holding (1) the search warrant that yielded a gun, a magazine, and ammunition lacked probable cause; and (2) the Commonwealth failed to present sufficient evidence to the grand jury to support the armed career criminal enhancements. View "Commonwealth v. Mora" on Justia Law

Mass. Gen. Laws ch. 209A requires law enforcement to take reasonable measures to serve abuse prevention orders, and in order for the service of the orders to be reasonable, the manner of service must comply with the terms of the Fourth Amendment to the United States Constitution and article 14 of the Massachusetts Declaration of Rights.A district court judge granted Defendant’s motion to suppress evidence relating to, and discovered as a result of, the stop of his vehicle, finding that the purpose of the stop was to serve an abuse prevention order. The Supreme Judicial Court answered in the negative a question reported by the judge asking whether chapter 209A authorizes the police to effectuate a motor vehicle stop to serve a civil abuse prevention order. The Supreme Judicial Court noted that whether a stop to serve a chapter 209A order is reasonable depends on an objective assessment of the necessity of doing so in light of all facts known to law enforcement at the time. View "Commonwealth v. Sanborn" on Justia Law

The designation of prima facie evidence in Mass. Gen. Laws ch. 266, 37 - pursuant to which an individual commits larceny if, with the intent to defraud, he obtains goods or services in exchange for a check that the individual wrote knowing there were insufficient funds in the account from which the check draws - and the instruction stemming from the statute are unconstitutional.Defendant appealed his conviction of four counts of larceny by uttering a false check, arguing that the prima facie designation in the statute and the related instruction are constitutionally infirm because an individual’s failure to pay a check within two days of notice of dishonor does not have a sufficiently logical connection to the individual’s knowledge of insufficient funds or intent to defraud at the time the check was written. The Supreme Judicial Court agreed with Defendant but nonetheless affirmed his convictions because the instructional error in this case was harmless beyond a reasonable doubt. View "Commonwealth v. Littles" on Justia Law

The Supreme Judicial Court affirmed the judgment of a single justice of the county court dismissing Petitioner’s petition for relief in the nature of certiorari pursuant to Mass. Gen. Laws ch. 249, 4. After Petitioner, a medical doctor, was terminated from his position, the Board of Registration in Medicine (board) commenced disciplinary proceedings against him. The board referred the matter to the Division of Administrative Law Appeals. Following an evidentiary hearing, a magistrate issued his recommended decision. Petitioner filed a complaint in the nature of petition for a writ of certiorari arguing, inter alia, that his due process rights had been violated during the course of the board proceedings. The single justice dismissed the petition without a hearing. The Supreme Judicial Court affirmed, holding that the single justice did not err or otherwise abuse his discretion in dismissing the petition. View "Padmanabhan v. Board of Registration in Medicine" on Justia Law