Justia Massachusetts Supreme Court Opinion Summaries

A jury found Earl T. Fulgiam and Michael T. Corbin guilty as joint venturers of murder in the first degree of Kevin Thomas, Jr. and Billie Marie Kee. The Supreme Judicial Court affirmed the convictions and declined to grant relief pursuant to Mass. Gen. Laws ch. 278, 33E, holding (1) the trial court did not err in admitting certain cellular telephone records; (2) the admission of fingerprint cards attributed to Defendants did not violate Defendants’ right to confront witnesses against them; (3) the trial judge did not err in admitting a fingerprint analyst’s testimony related to the fingerprint analysis; and (4) the prosecutor permissibly inferred that a “team” of men committed the murders. View "Commonwealth v. Fulgiam" on Justia Law

The Supreme Judicial Court affirmed Defendant’s conviction for murder in the first degree on theories of extreme atrocity or cruelty and deliberate premeditation, holding that there was no error in this case warranting reversal, nor was there any reason for the Court to exercise its authority under Mass. Gen. Laws ch. 278, 33E to reduce the verdict or order a new trial. Specifically, the Supreme Judicial Court held (1) the trial court did not err in denying Defendant’s motion to suppress a statement Defendant made to police; (2) the evidentiary rulings challenged by Defendant were unavailing; (3) there was no prejudicial error in the jury instructions; (4) the trial judge did not abuse his discretion in failing to dismiss several jurors for cause; (5) any potential prejudice to Defendant from the prosecutor’s closing argument was mitigated by a comprehensive limiting instruction; and (6) Defendant’s mandatory sentence of life in prison without the possibility of parole is constitutional. View "Commonwealth v. Colton" on Justia Law

Petitioner appealed from the denial of his petition filed pursuant to Mass. Gen. Laws ch. 211, 3 after the Housing Court entered judgment in Respondent’s favor in a summary process action. Petitioner filed a motion to waive the appeal bond, which was allowed. Respondent appealed. A single justice held a hearing on the matter and remanded the matter to the Housing Court for a determination of the amount of use and occupancy installment payments Petitioner should make to Respondent while his appeal was pending. Petitioner appealed, but a single justice determined that there was no right of appeal under the circumstances. Petitioner then filed a document that the single justice treated as a Mass. Gen. Laws ch. 211, 3 petition and denied. The Supreme Judicial Court affirmed, holding that the single justice acted within her discretion in denying the petition under the circumstances. View "Pare v. Harmony House, Inc." on Justia Law

Appellant appealed the denial of two Mass. Gen. Laws ch. 211, 3 petitions he filed related to ongoing trial court proceedings. The subject petitions were the fourth and fifth such petitions Appellant had filed in the county court seeking extraordinary relief from interlocutory trial courts rulings or otherwise related to ongoing trial court proceedings. The Supreme Judicial Court affirmed the judgments and placed Appellant on notice that any subsequent attempt to seek relief pursuant to Mass. Gen. Laws ch. 211, 3, where Appellant has an adequate alternative remedy or fails to comply with S.J.C. Rule 2:21, may result in restriction of future filings or other action by the Court. View "Afrasiabi v. Commonwealth" on Justia Law

Appellant filed a Mass. Gen. Laws ch. 211, 3 petition seeking interlocutory relief from an order of the superior court temporarily committing him to the Massachusetts Treatment Center pursuant to Mass. Gen. Laws ch. 123A, 12(e) pending a probable cause determination on the Commonwealth’s petition for Appellant’s civil commitment as a sexually dangerous person. A single justice denied relief on the ground that Appellant had an adequate remedy in the ordinary appellate process. The Supreme Judicial Court affirmed, holding that all of Appellant’s arguments as to the merits of his petition could be raised on appeal from an adverse final judgment in this matter. View "Schumacher v. Commonwealth" on Justia Law

Following a series of disciplinary reprimands and suspensions for misconduct, Plaintiff was removed from her positions as an assistant clerk-magistrate of the Salem Division of the District Court Department. Plaintiff brought this action challenging her removal, arguing that the decision to remove her exceeded the clerk-magistrate’s statutory authority, was arbitrary or capricious, and violated her due process rights. The superior court upheld the removal decision. The Supreme Judicial Court affirmed, holding that it was appropriate for the clerk-magistrate to factor in the whole of Plaintiff’s disciplinary record in terminating her, and therefore, the clerk-magistrate’s decision was not arbitrary or capricious, due process was satisfied, and Plaintiff demonstrated no deviation from the governing statute or rules. View "Perullo v. Advisory Committee on Personnel Standards" on Justia Law

Plaintiff filed a complaint alleging that Zurich American Insurance Co. committed unfair claim settlement practices in violation of Mass. Gen. Laws ch. 176D, 3(9)(f) and Mass. Gen. Laws ch. 93A, 2. Specifically, Plaintiff claimed that Zurich violated these statutory provisions when it conditioned the payment of its primary insurance policy limit on a release of all claims against its insureds, notwithstanding the availability of excess insurance. The superior court judge concluded that Zurich was entitled to judgment as a matter of law because it did not engage in unfair claim settlement practices. The Supreme Judicial Court affirmed, holding that Zurich did not engage in unfair claim settlement practices in violation of Mass. Gen. Laws ch. 176D, 3(9)(f) and Mass. Gen. Laws ch. 93A, 2. View "Caira v. Zurich American Insurance Co." on Justia Law

Defendant was charged with offenses arising from alleged domestic violence. The Commonwealth and Defendant filed motions in limine regarding the admissibility of a record of a 911 call placed by the son of Defendant and the alleged victim. Defendant argued that the boy’s statements - including, “my dad just choked my mom” - were not excited utterances and that their admission would violate his right of confrontation right. The judge concluded that the statements were not excited utterances because the boy’s voice on the recording sounded “calm.” A single justice vacated the judge’s order excluding the recording. The Supreme Judicial Court affirmed, holding that the question is not whether the declarant shows “excitement,” but, rather, whether the declarant was acting spontaneously under the influence of the incident at the time the statements were made, and not reflexively. Remanded. View "Commonwealth v. Baldwin" on Justia Law

After a jury trial, Defendant was convicted of raping his nineteen-year-old stepdaughter, Sally. Defendant and Sally’s mother were married. The Appeals Court reversed, concluding that Sally was precluded from testifying about a private marital conversation between her mother and Defendant, the substance of which Sally’s mother had purportedly disclosed to her. Specifically, at trial, the mother denied that she told Sally that Defendant had confessed to the crime in a private conversation between the parties. To impeach the mother, however, Sally was permitted to testify to the contrary. The Supreme Judicial Court reversed Defendant’s conviction on other grounds, holding that the admission of this highly prejudicial evidence created a substantial risk of a miscarriage of justice. View "Commonwealth v. Garcia" on Justia Law

A complaint issued charging Defendant with misleading a police officer. The charge arose from Defendant’s act of picking up a small bag of what was believed to be heroin and swallowing it in full view of a police officer. A municipal court judge dismissed the count. The Appeals Court vacated the dismissal. The Supreme Judicial Court affirmed the order of the trial court judge allowing the motion to dismiss, holding (1) misleading conduct within the meaning of Mass. Gen. Laws ch. 268, 13B is conduct that is intended to create a false impression such that it was reasonably likely to send investigators in the wrong direction; and (2) in the instant case, Defendant’s actions were not misleading within the meaning of the statute. View "Commonwealth v. Tejeda" on Justia Law