Justia Massachusetts Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted on two indictments charging violations of Mass. Gen. Laws ch. 268, 13B, the witness intimidation statute, which prohibits “willfully…mislead[ing]…[a] police officer.” Defendant's convictions arose from his conduct at two separate interviews with police during their investigation of a fight at a party Defendant hosted. Defendant appealed, arguing that the jury was incorrectly instructed regarding the elements of section 13B and that his motions for required findings of not guilty should have been allowed. The Supreme Judicial Court vacated the judgments of conviction, holding (1) the jury instruction regarding the “misleading” element of section 13B was incorrect; and (2) if the jury had been properly instructed, the evidence would have been sufficient to allow the jury to find Defendant guilty of violating section 13B at the first interview but not at the second interview. Remanded for entry of a required finding of not guilty with respect to the second indictment and for further proceedings consistent with this opinion. View "Commonwealth v. Paquette" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree and related offenses. The Supreme Judicial Court affirmed Defendant's convictions and declined to grant relief pursuant to Mass. Gen. Laws ch. 278, 33E, holding that the trial judge did not err by (1) denying Defendant’s motion for a required finding of not guilty; (2) admitting into evidence certain items that were seized from an apartment building owned by Defendant's parents; (3) permitting jurors to ask questions of the witnesses; (4) admitting or excluding certain testimonial evidence offered by various witnesses; and (5) denying Defendant’s request for a jury instruction on transferred intent. View "Commonwealth v. Gomes" on Justia Law

Plaintiff, a Massachusetts prison inmate, brought civil rights action claiming that Defendants violated his constitutional right to due process by holding him in a special management unit (SMU) - or solitary confinement - for ten months without a hearing while waiting to reclassify or transfer him. The Supreme Judicial Court held that segregated confinement on awaiting action status for longer than ninety days gives rise to a liberty interest entitling an inmate to notice and a hearing. On remand, the superior court entered declaratory judgment in favor of Plaintiff and awarded him attorney’s fees and costs. Defendants appealed, arguing that Plaintiff was not a prevailing party under 42 U.S.C. § 1988(b) because he had been discharged from SMU detention long before he won any relief, and therefore, the declaratory judgment was moot and did not directly benefit him or materially alter his relationship with Defendants. The Supreme Judicial Court affirmed, holding (1) Plaintiff did qualify as a prevailing party in the circumstances of this case; and (2) the award of fees to Plaintiff was reasonable. View "LaChance v. Commissioner of Correction" on Justia Law

Plaintiffs in this putative class action were inmates serving criminal sentences in various Massachusetts prison facilities who had, for varying lengths of time, been placed in a special management unit (SMU) in nondisciplinary administrative segregation. Plaintiffs brought this action alleging that their placements in the SMUs violated their constitutional rights to due process, as well as regulations of the Department of Correction. Plaintiffs sought to represent a class of similarly situated prisoners confined in SMUs. A judge denied Plaintiffs’ motion for class certification and, relying on the Supreme Judicial Court’s decision in LaChance v. Commissioner of Correction, dismissed Plaintiffs’ complaint. The Appeals Court dismissed Plaintiffs’ appeal as moot, as, by then, no named plaintiffs remained in SMUs. The Supreme Judicial Court reversed, holding (1) in light of the class action allegations in Plaintiffs’ complaint, the appeal was not moot; and (2) LaChance did not resolve the merits of all of Plaintiffs’ claims. Remanded. View "Cantell v. Commissioner of Correction" on Justia Law

After a jury trial, Defendant was convicted of one count of rape of a child. The underlying indictment alleged that Defendant raped his daughter on diverse dates between 1979 and 1981. Defendant appealed, raising statute of limitations claims. The Supreme Judicial Court vacated Defendant’s conviction, holding (1) the Commonwealth presented sufficient evidence from which the jury could determine that the indictment was timely returned, but the jury instruction concerning how to make this determination was incorrect, which resulted in a substantial risk of a miscarriage of justice; (2) the required independent corroboration of any incidents of rape that occurred more than twenty-seven years before the indictment was returned must relate to the specific criminal act or acts of which a defendant is accused, and evidence of uncharged misconduct does not suffice; and (3) the Commonwealth’s corroborative evidence consisting only of evidence of uncharged misconduct was insufficient as a matter of law. Remanded for a new trial. View "Commonwealth v. White" on Justia Law

Defendant was convicted as a joint venturer of murder in the first degree, armed robbery, and assault and battery by means of a dangerous weapon. The Supreme Judicial Court affirmed the convictions and discerned to reason to exercise its authority to grant extraordinary relief, holding (1) the trial court did not err in denying Defendant’s motions for required findings of not guilty, as the evidence was sufficient to support the convictions; (2) the trial court did not err in denying Defendant’s motion to dismiss on speedy trial grounds, as Defendant acquiesced to an additional period of delay; and (3) certain evidence, including Defendant’s oral statements to police, was properly admitted at trial. View "Commonwealth v. Williams" on Justia Law

After a jury trial, Defendant was found guilty of possession with intent to distribute heroin and possession with intent to distribute cocaine. Defendant pleaded guilty to the subsequent offense portion of each of these charges. After a hearing, the trial judge stated that she would depart downward from the mandatory minimum sentence provisions of the two subsequent offense statutes. The Commonwealth filed a petition for relief pursuant to Mass. Gen. Laws ch. 211, 3. The Supreme Court allowed the Commonwealth’s petition for relief and vacated Defendant’s sentences, holding that because the Legislature has not yet enacted into law sentencing guidelines recommended by the Massachusetts Sentencing Commission, Mass. Gen. Laws ch. 211E, 3(e) does not authorize a sentencing judge to depart from the mandatory minimum terms specified by statute for subsequent drug offenses. View "Commonwealth v. Laltaprasad" on Justia Law

Defendant owned and managed a nature preserve on Martha’s Vineyard compromised of parcels of land owned by Defendant. In 2010, Defendant created a hiking trail through the preserve that crossed over Plaintiffs’ property via an easement. The trail proceeded across three parcels of Defendant’s land for whose benefit the easement was created and then entered a fourth parcel owned by Defendant that was not intended to benefit from the easement. Plaintiffs filed an action to prevent Defendant from using the easement as part of the hiking trial, arguing that the bright-line rule in Murphy v. Mart Realty of Brockton, Inc. disallows any use of an easement to benefit land to which the easement is not appurtenant. On that basis, a land court judge granted partial summary judgment in favor of Plaintiffs. Defendant appealed, arguing that the bright-line rule in Murphy is overly rigid and suggested, instead, that the Court adopt a fact-intensive inquiry considering whether the use of an easement to benefit other parcels would increase unfairly the burden on the easement. The Supreme Judicial Court affirmed and thus declined to adopt Defendant’s suggestion, holding that the benefits of preserving the bright-line rule set forth in Murphy outweigh any costs associated with its rigidity. View "Taylor v. Martha's Vineyard Land Bank Comm’n" on Justia Law

Plaintiff sued her employer for sex discrimination, race discrimination, and retaliation under Mass. Gen. Laws ch. 151B, 9. The jury found in favor of Plaintiff on her retaliation claim and awarded her both compensatory and punitive damages. Defendant was additionally ordered to pay attorney’s fees and costs. The judgment did not provide for postjudgment interest on punitive damages, costs, and attorney’s fees. Plaintiff appealed, arguing that her request for postjudgment interest should have been granted. The Supreme Judicial Court affirmed the judgment, holding that the trial judge correctly denied Plaintiff’s request for postjudgment interest on the award of punitive damages, costs, and attorney’s fees because Mass. Gen. Laws ch. 151B, 9 does not contain language that necessarily implies that the Commonwealth should be liable for such postjudgment interest. View "Brown v. Office of Comm’r of Probation" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree and assault and battery with a dangerous weapon. The Supreme Judicial Court reversed the convictions and remanded the case for a new trial due to errors in Defendant’s first trial. On remand, Defendant was convicted of murder in the first degree by extreme atrocity or cruelty and assault and battery by means of a dangerous weapon. Defendant was sentenced to life in prison without the possibility of parole on the murder conviction. The Supreme Judicial Court affirmed on appeal, holding (1) the Commonwealth made improper statements during closing arguments, but this error did not warrant a new trial or other relief; (2) Defendant’s remaining allegations of error were unavailing; and (3) the Court discerns no basis to grant relief pursuant to Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Durand" on Justia Law