Justia Massachusetts Supreme Court Opinion Summaries

After a jury-waived trial, Defendant was found guilty of breaking and entering in the daytime with the intent to commit a felony and larceny of property over $250. Defendant’s fingerprint at the crime scene constituted the only identification evidence. On appeal, Defendant argued that the evidence was insufficient to support the convictions. The Appeals Court affirmed. The Supreme Judicial Court reversed, holding that the evidence was not sufficient to find, beyond a reasonable doubt, that Defendant left his fingerprint at the time of the break-in, and therefore, there was insufficient evidence to support the convictions. View "Commonwealth v. French" on Justia Law

This case concerned the arrival in Massachusetts of four minor siblings from a Nepalese refugee camp through a minor refugee program. The children’s parents subsequently arrived, but had very limited contact with the children after their arrival. The Department of Children and Families petitioned the probate and family court to free the children for adoption by terminating parental rights. The mother moved to deny the petition. The judge denied the motion and reported the matter to the appeals court, asking whether the Code of Federal Regulations allows the Department to petition for termination of parental rights under the circumstances of this case. The Supreme Judicial Court affirmed the judge’s denial of the mother’s motion to deny the Department’s petition, holding that the Code of Federal Regulations allows the Department to proceed to seek a termination of parental rights where unaccompanied refugee minors are present in the United States pursuant to the minor refugee program and the parents arrive in the United States but make no attempt to reunite with their children. View "In re Adoption of Yadira" on Justia Law

This lawsuit arose from the explosion on the oil rig Deepwater Horizon that caused 4.9 million barrels of oil to flow into the Gulf of Mexico. Defendants, environmental activists, contributed an article appearing in an Internet Web site that contained criticism of Plaintiff, a scientific consulting firm retained to assess the toxic effects of the oil spill on cleanup workers. Plaintiff brought claims for defamation in Massachusetts and in New York. Defendants filed a special motion to dismiss the Massachusetts suit under the anti-SLAPP statute, Mass. Gen. Laws ch. 231, 59H. The superior court denied the motion, concluding that Defendants failed to meet their threshold burden of showing that the suit was based exclusively on the exercise of their right of petition under the Constitution. The Supreme Judicial Court reversed, holding (1) Defendants met their threshold burden because they were engaged in protected petitioning activity; and (2) Plaintiff could not show that such petitioning was devoid of reasonable factual support or arguable basis in law and therefore could not defeat the special motion. View "Cardno ChemRisk, LLC v. Foytlin" on Justia Law

A grand jury returned indictments against Defendant on various charges, including three counts of armed assault with intent to murder and murder in the second degree. Defendant moved to suppress the identification of him by an eyewitness, Brianna Johnson, and also moved to suppress Johnson’s identification of a firearm as the one used by Defendant in the commission of the crime. The motion judge denied the motion to suppress the identification of Defendant but allowed the motion to suppress the identification of the firearm. The Supreme Judicial Court affirmed, holding (1) under the circumstances of this case, the failure to detectives showing a photographic array to the eyewitness to use the protocol outlined in Commonwealth v. Silva-Santiago did not warrant suppression of Defendant’s identification of Defendant; (2) the use of a simultaneous rather than a sequential display of photographs in an array was not unnecessarily suggestive; and (3) the motion judge did not abuse his discretion in ruling the identification of the firearm as inadmissible under the common law of evidence due to suggestive police questioning and subsequent police confirmation. View "Commonwealth v. Thomas" on Justia Law

Defendant was charged with disorderly conduct. The charge arose from Defendant’s behavior as a patient in the psychiatric area of the emergency department at a Boston hospital. Defendant appealed, arguing that there was insufficient evidence to support his conviction. The Supreme Judicial Court reversed Defendant’s conviction, vacated the judgment, and remanded to the municipal court for entry of a judgment of dismissal, holding that the evidence was not sufficient to permit a reasonable jury to find beyond a reasonable doubt that Defendant consciously disregarded a “substantial and unjustifiable risk of public inconvenience, annoyance, or alarm.” View "Commonwealth v. Accime" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on the theory of deliberate premeditation. The Supreme Judicial Court affirmed Defendant’s convictions and declined to grant relief under Mass. Gen. Laws ch. 278, 33E, holding (1) the trial judge did not err by permitting the Commonwealth’s expert witness to opine that Defendant’s behavior was planned and goal-directed; (2) the trial judge did not erroneously permit the same expert to state the bases of her opinion on direct examination; and (3) the prosecutor did not make statements not supported by the evidence during closing arguments. View "Commonwealth v. Goddard" on Justia Law

Alexander Soto was a juvenile when he was indicted for murder in the first degree and related offenses. The superior court dismissed the non-murder indictments, concluding that the nonmurder charges must first be brought in the juvenile court by a complaint for delinquency or a youthful offender indictment prior to joinder with the murder indictments. The Supreme Judicial Court reversed the order allowing Soto’s motion to dismiss the non-murder indictments, holding that, when a juvenile is indicted for murder, non-murder offenses that are properly joined with the murder indictment must be brought in the superior court. View "Commonwealth v. Soto" on Justia Law

During the divorce proceedings of Husband and Wife, Wife did not pursue her claim for alimony. Four years after the divorce judgment, Wife sought and obtained an alimony award. Both parties appealed. On appeal, both parties agreed that the judge erred by commencing the durational limit of alimony on the date of the first temporary alimony payment but disagreed on the appropriate commencement date. The Supreme Judicial Court remanded the case with instructions to reevaluate the alimony judgment, holding (1) under the circumstances, the durational limit of general term alimony under Mass. Gen. Laws ch. 208, 49(b) starts to run on the date that the alimony was awarded, not on the date of the divorce judgment or on the date temporary alimony was awarded; (2) the income earned from overtime pay must be considered in making an initial alimony award determination under Mass. Gen. Laws ch. 208, 34, regardless of whether that determination is made before or after the divorce judgment; and (3) where a judge awards alimony under section 34, the judge must specifically address the issue of health insurance coverage for the recipient spouse. View "Snow v. Snow" on Justia Law

After a jury-waived trial, Defendant was convicted of one count of possession of child pornography with the intent to disseminate, one count of dissemination of child pornography, and three counts of possession of child pornography. Defendant appealed on three grounds. The Supreme Judicial Court affirmed, holding (1) the search warrant for the apartment in which Defendant was living was appropriately particularized; (2) the administrative subpoena that issued under Mass. Gen. Laws ch. 271, 17B for Internet service records was valid; and (3) the Commonwealth met the requirement of proving that Defendant had the lascivious intent necessary to support a conviction under Mass. Gen. Laws ch. 272, 29B. View "Commonwealth v. Molina" on Justia Law

After a jury trial, Defendant was convicted of possessing child pornography. Defendant appealed, arguing that the district court erred in denying his motion to suppress computer evidence obtained pursuant to a search warrant issued for the the place searched because the police needed more information to link Defendant to the place searched and the items seized. The Supreme Judicial Court affirmed, holding that there was a substantial basis from which to conclude that the evidence of downloading and sharing child pornography via the Internet was probably present at the place to be searched. View "Commonwealth v. Martinez" on Justia Law