Justia Massachusetts Supreme Court Opinion Summaries
Commonwealth v. Holland
After a jury trial, Defendant was convicted of murder in the first degree on the theories of deliberate premeditation and extreme atrocity or cruelty, and armed home invasion. After filing a notice of appeal, Defendant filed a motion for a new trial arguing that his trial counsel was constitutionally ineffective for failing to investigate and present a defense of lack of criminal responsibility. Defendant also filed a second motion for a new trial. The trial court denied Defendant’s two motions for a new trial. The Supreme Judicial Court affirmed Defendant’s convictions and the orders denying the motions for a new trial and declined to reduce the verdict or grant a new trial, holding (1) the trial judge did not err in denying Defendant’s first motion for a new trial, as trial counsel’s decision to forgo further investigation of a lack of criminal responsibility defense based on mental illness was not error; and (2) Defendant’s remaining claims of error were either procedurally waived or without merit. View "Commonwealth v. Holland" on Justia Law
Gannon v. City of Boston
For the first decade of his employment with the Boston police department, Plaintiff was a patrol officer performing the full range of patrol officer duties. The department later placed Plaintiff on administrative duty due to his loss of cognitive function and memory and his “neuropsychological problem of speed and accuracy.” The Boston Patrolmen’s Association subsequently filed a grievance on Plaintiff’s behalf demanding that he be permitted to resume the duties of a patrol officer. An arbitrator found that the Department did not act unreasonably in placing Plaintiff on administrative duty. Plaintiff filed a discrimination lawsuit against the city. The motion judge allowed the city’s motion for summary judgment. The Supreme Judicial Court reversed, holding that summary judgment was not appropriate because there were facts in dispute as to whether Plaintiff was a qualified handicapped person capable of performing the full duties of a patrol officer without posing an unacceptably significant risk of serious injury to himself or others. View "Gannon v. City of Boston" on Justia Law
Posted in:
Civil Rights, Labor & Employment Law
Commonwealth v. Morgan
Defendant, a veteran of the United States Army, was arraigned in the district court on charges of operating a motor vehicle while under the influence of alcohol or drugs (OUI), second offense; possession of heroin; negligent operation of a motor vehicle; and leaving the scene of property damage. Defendant sought pretrial diversion under the VALOR Act. Defendant subsequently filed a motion pursuant to the pretrial diversion statute seeking dismissal of all charges should the pretrial diversion program prove successful. The prosecutor opposed the motion. Acknowledging that the case presented an unsettled question of law, the judge reported the following two questions to the Appeals Court. The Supreme Judicial Court allowed Defendant’s application for direct appellate review and held (1) under the pretrial diversion statute, as amended by the VALOR Act, a judge is authorized to dismiss or to continue criminal charges without a finding upon a defendant’s successful completion of an approved pretrial diversion program; and (2) the pretrial diversion statute, as amended by the VALOR Act, vests judges with discretion to either continue without a finding or to dismiss a charge of OUI in appropriate cases that involve charges of OUI, second or subsequent offense. View "Commonwealth v. Morgan" on Justia Law
Posted in:
Criminal Law
In re Guardianship of K.N.
In 2005, a few weeks after Child was born, Child's Grandmother was appointed as Child’s permanent guardian and has remained so ever since. Mother filed this removal proceeding challenging the guardianship arrangement. In 2016, Child, through counsel, filed a motion to appoint counsel for her guardian. The motion was denied. The Supreme Judicial Court remanded the case to the probate and family court for further proceedings, holding (1) a guardian who has a de facto parent relationship with her ward does not have a liberty interest in that relationship such that she has a procedural due process right to counsel; but (2) a probate and family court judge may, in the exercise of his sound discretion, grant a motion requesting counsel for a guardian in a removal proceeding where the judge concludes that doing so would materially assist in determining the best interests of the child. View "In re Guardianship of K.N." on Justia Law
Commonwealth v. Felix
After a jury trial, Defendant was convicted of murder in the first degree on the theory of deliberate premeditation. Defendant was sentenced to life in prison without parole. The Supreme Judicial Court affirmed Defendant’s conviction and the order denying his motion for a new trial and declined to grant relief under Mass. Gen. Laws ch. 278, 33E, holding (1) Defendant’s trial counsel did not render ineffective assistance by failing to request a jury instruction on voluntary manslaughter; (2) the trial court did not commit reversible error by declining Defendant’s request to give instructions on voluntary and involuntary manslaughter; and (3) the absence of these instructions did not constitute error requiring reversal of Defendant’s conviction and a new trial. View "Commonwealth v. Felix" on Justia Law
Posted in:
Criminal Law
Commonwealth v. Ackerman
Defendant was charged with operating while under the influence of intoxicating liquor, second offense, and a marked lanes violation. The charges stemmed from a single vehicle accident in which the vehicle Defendant was driving rolled over. Defendant filed a motion in limine to exclude from her medical records evidence of a blood alcohol test taken after she was transported to the hospital based on her right to confrontation under the Sixth Amendment. A district court judge allowed the motion. A single justice vacated the trial judge’s order allowing the motion in limine and ordered that the blood alcohol test evidence was admissible. The Supreme Judicial Court affirmed, holding that it was “eminently logical” that the blood alcohol test administered to Defendant was performed as a routine medical practice in the course of Defendant’s treatment following the accident. View "Commonwealth v. Ackerman" on Justia Law
Commonwealth v. Gulla
Defendant was convicted of murder in the first degree on the theories of deliberate premeditation and extreme atrocity or cruelty. The Supreme Judicial Court affirmed Defendant’s convictions and the trial court’s denial of his motion for a new trial and declined to grant extraordinary relief pursuant to Mass. Gen. Laws ch. 278, 33E, holding (1) Defendant received constitutionally effective assistance of counsel at trial; (2) Defendant was given a meaningful opportunity to present a complete defense; and (3) the trial judge did not deprive Defendant of his right to a fair trial by denying Defendant’s request to give a voluntary manslaughter instruction. View "Commonwealth v. Gulla" on Justia Law
Commonwealth v. Sanchez
After a jury trial, Defendant was convicted of murder in the first degree on theories of deliberate premeditation and extreme atrocity or cruelty, arson of a dwelling house, and violating an abuse prevention order. The Supreme Judicial Court affirmed the convictions and declined to reduce the degree of guilt or to order a new trial, holding (1) the evidence was sufficient to support Defendant’s convictions of murder in the first degree and arson; (2) the testimony of two expert witnesses did not violate Defendant’s right to confrontation under the Sixth Amendment; (3) Defendant’s custodial statements to police were obtained with a valid Miranda waiver and were voluntary; and (4) the motion judge did not abuse his discretion in denying Defendant’s motion for a new trial without an evidentiary hearing. View "Commonwealth v. Sanchez" on Justia Law
State Board of Retirement v. Finneran
In 2007, Thomas Finneran, former Speaker of the House, pleaded guilty in federal district court to one count of obstruction of justice. The conviction stemmed from false testimony that Finneran had provided in relation to a federal court action challenging the 2001 redistricting act. Immediately after Finneran’s conviction, the State Retirement Board ceased payments of Finneran’s pension on the ground of his conviction under Mass. Gen. Laws ch. 32, 15(4). The hearing officer concluded that Finneran’s crime required the forfeiture of his pension under the statute because he had “been convicted of a criminal offense involving violation of the laws applicable to his office or position.” A municipal court judge reversed, concluding that there was no direct link between Finneran’s conviction and his position as a House Member and/or Speaker. The Supreme Judicial Court affirmed, holding that Finneran’s conviction of obstruction of justice was a “violation of the laws applicable to his office or position” and, therefore, required the statutory forfeiture of his pension. View "State Board of Retirement v. Finneran" on Justia Law
Posted in:
Criminal Law, Labor & Employment Law
Commonwealth v. Squires
After a joint jury trial, Defendants - John Squires and Steven Angier - were convicted of walking on a railroad track and possession of burglarious instruments. Defendants separately appealed, arguing, inter alia, that there was insufficient evidence to sustain the convictions of possession of burglarious implements. The Appeals Court affirmed. The Supreme Judicial Court reversed the judgments with respect to Defendants’ convictions of possession of burglarious instruments, holding that the Commonwealth failed to establish proof beyond a reasonable doubt of all of the elements of possession of burglarious instruments, and therefore, the evidence was insufficient to support the convictions. View "Commonwealth v. Squires" on Justia Law
Posted in:
Criminal Law