Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed Appellant’s convictions for two counts of murder in the first degree on the theories of felony murder, deliberate premeditation, and extreme atrocity or cruelty and the order denying his motion for a new trial and declined to set aside the verdicts or reduce the degree of guilt under Mass. Gen. Laws ch. 278, 33E. Defendant was convicted as a joint venturer. His coventurer was tried separately and convicted of the victims’ murders. The Supreme Judicial Court held that there was no error warranting dismissal of the indictments or reversal of the convictions. View "Commonwealth v. Rakes" on Justia Law

Mass. Gen. Laws ch. 276, 100A(6), the provision of a statute that retroactively prohibits Plaintiff from sealing the record of her sex offenses because she was once classified as a level two sex offender, as applied to Plaintiff, is both retroactive and unreasonable, and therefore, State constitutional due process precludes the Supreme Court from enforcing it against her.Plaintiff argued that the retroactive statutory prohibition on sealing sex offenses violated her due process rights under the Massachusetts Declaration of Rights because the Sex Offender Registry Board had determined that Plaintiff no longer posed any cognizable degree of dangerousness or risk of reoffending, no longer believed she should be classified as a level two sex offender, and had relieved her of the obligation to register as a sex offender. The Supreme Judicial Court agreed with Plaintiff, holding that section 100A applies retroactively to Plaintiff and is unreasonable in its application to her. View "Koe v. Commissioner of Probation" on Justia Law

The Supreme Judicial Court remanded this divorce action to the probate and family court with instructions to reevaluate the alimony judgment in light of this opinion and enter a new judgment accordingly. The court held (1) where the supporting spouse has the ability to pay, the need for support of the recipient spouse under general term alimony is the amount required to enable her to maintain the standard of living she had at the time of the separation leading to the divorce, not the amount required to enable her to maintain the standard of living she would have had in the future if the couple had not divorced; and (2) although there might be circumstances where it is reasonable a fair to award a percentage of the supporting spouse’s income as general term alimony to the recipient spouse, those circumstances were not present in this case. View "Young v. Young" on Justia Law

In this case, the Supreme Judicial Court addressed the scope of criminal liability under the common-law felony-murder rule. A unanimous court concluded that the felony-murder rule is constitutional, but a majority of justices concluded that the scope of felony-murder liability should be prospectively narrowed. The court held that, in trials that commence after the date of the opinion in this case, a defendant may not be convicted of murder without proof of one of the three prongs of malice. The court held that, in the future, felony-murder is no longer an independent theory of liability for murder but is rather limited to its statutory role under Mass. Gen. Laws ch. 265, 1 as an aggravating element of murder. The majority ruled that this holding is prospective in effect and therefore does not affect the judgment reached in this case, where Defendant was convicted of two counts of felony-murder in the first degree based on the predicate felonies of an attempted commission of armed robbery, home invasion, unlawful possession of a firearm, and unlawful possession of ammunition. View "Commonwealth v. Brown" on Justia Law

The Supreme Judicial Court vacated Defendant’s convictions of two charges of possession of the ingredients to make an incendiary device or substance with the intent to do so, in violation of Mass. Gen. Laws ch. 266, 102(a), and remanded the matter for entry of required findings of not guilty, holding that the evidence presented at trial was not sufficient to establish every element of the Commonwealth’s case. Specifically, the court held that the evidence introduced at trial was insufficient to establish that Defendant was without lawful authority to possess three bags of different powders or the incidendiary substance, thermite, that the Commonwealth asserted that Defendant intended to make. View "Commonwealth v. Aldana" on Justia Law

To the extent that field sobriety tests (FSTs) are relevant to establish a driver’s balance, coordination, mental acuity, and other skills required to operate a motor vehicle safely, FSTs are admissible at trial as observations of the police officer conducting the assessment. However, neither a police officer nor a lay witness who has not been qualified as an expert may offer an opinion as to whether a driver was under the influence of marijuana.Defendant was charged with operating a motor vehicle under the influence of marijuana. Defendant filed a motion for a Daubert-Lanigan hearing seeking to challenge the admissibility of evidence concerning his performance on FSTs conducted after the stop. The Supreme Court heard oral argument in the matter and then answered the reported questions as set forth above and remanded the case to the district court for further proceedings. View "Commonwealth v. Gerhardt" on Justia Law

At issue in this case was the construction of Mass. Gen. Laws ch. 156D, 14.30, the corporate dissolution statute, which allows a shareholder to petition a judge of the superior court to dissolve a corporation in the event of a deadlock between its directors. Plaintiff and Defendant were the sole shareholders and directors of a corporation. Plaintiff filed a petition pursuant to the corporate dissolution statute seeking to dissolve the corporation. After a jury-waived trial, Plaintiff also filed a separate claim for contempt of court. Defendant counterclaimed. A judge rejected all of Plaintiff’s claims and Defendant’s counterclaims. The Supreme Judicial Court remanded the matters, holding (1) the impasse as to fundamental matters of corporate governance and operations existing under these circumstances gave rise to a state of “true deadlock” such that the remedy of dissolution provided by the statute was allowable; (2) because dissolution is a discretionary remedy, the superior court must make a determination as to whether it is the appropriate remedy under the circumstances; and (3) the superior court must consider the allegations raised in the complaint for contempt concerning conduct that occurred after the trial. View "Koshy v. Sachdev" on Justia Law

A mother may intervene both on her own behalf and on behalf of her children in an eviction action brought by a landlord against the mother’s husband and their young children where the mother has lived with her family in the apartment throughout the tenancy and alleges domestic violence in the home, despite her not being a named tenant on the lease. The mother in this case (Mother) appealed from the denial by a judge of the housing court of her motion to intervene in a summary process action brought by Landlord. Because Mother’s husband did not appear, the judge entered a judgment of default. The Supreme Court vacated both the denial of the motion to intervene and the judgment of default and remanded the case, holding (1) Mother was permitted to assert affirmative defenses to the eviction action on behalf of herself and her children; and (2) the motion judge prematurely reached the merits of the case. View "Beacon Residential Management, LP v. R.P." on Justia Law

The Supreme Judicial Court affirmed Defendants’ convictions of murder in the first degree and other offenses related to the home invasion but remanded for resentencing Swinkles Laporte’s convictions of home invasion and armed robbery while masked. The court held (1) there was no substantial likelihood of a miscarriage of justice arising from the failure of counsel to object to an in-court identification of Defendants - Laporte and Maxwell Wiggins - as the perpetrators; (2) the trial court did not err in denying Wiggins’ motions to sever and for a mistrial based on a previously suppressed out-of-court identification; (3) there was no reversible error in the trial court’s remaining challenged evidentiary rulings; (4) any error in the prosecutor’s closing argument did not influence the jury’s verdicts; but (5) Laporte’s nonmurder sentences are vacated and remanded for resentencing where Laporte’s murder sentence was revised because he was a juvenile at the time of the offense. View "Commonwealth v. Wiggins" on Justia Law

A police officer, responding to a report of an unauthorized person at Milton High School, searched the defendant's backpack and discovered a firearm, money, and marijuana. The defendant unsuccessfully moved to suppress the evidence, arguing that the police officer lacked a constitutionally permissible basis for the pat-frisk and the subsequent search. He was convicted of carrying a firearm without a license, G.L. c. 269, 10(a); carrying a dangerous weapon on school grounds, 269, 10(j); possession of a firearm without a firearm identification card, 269, 10(h); disturbing a school, 272, 40; and possession of a class D substance with intent to distribute, 94C, 32C. The Massachusetts Supreme Judicial Court vacated, stating that when a police officer conducts a pat-frisk, the applicable standard for assessing its constitutionality is reasonable articulable suspicion under Terry v. Ohio and that an officer's conduct in a school setting is governed by the traditional Fourth Amendment standard. Applying the Terry standard to this case, the officer lacked reasonable articulable suspicion that the defendant had committed a crime and the circumstances of the encounter did not warrant a reasonable belief that the defendant was armed and dangerous. Nor was the search permissible under any exception to the warrant requirement. View "Commonwealth v. Villagran" on Justia Law