Justia Massachusetts Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of, among other crimes, murder in the first degree on a theory of felony murder, based on the predicate felony of armed robbery. The Supreme Judicial Court vacated Defendant’s armed robbery conviction and affirmed his remaining convictions, holding (1) Defendant’s armed robbery conviction was the predicate felony for his felony-murder conviction, the only theory on which the jury found Defendant guilty of murder in the first degree, and therefore, the armed robbery conviction was duplicative; and (2) no other prejudicial error occurred during Defendant’s trial, and there was no other basis to exercise the Court’s authority pursuant to Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Carter" on Justia Law

After a jury trial, Defendant was convicted of operating a motor vehicle while under the influence of intoxicating liquor. The Supreme Judicial Court affirmed the conviction, holding (1) the trial court did not err in admitting evidence of Defendant’s failure to properly perform a breathalyzer test after giving consent, as the evidence was not inadmissible as refusal evidence; (2) the admission of the police-appointed interpreter’s English language version of Defendant’s statements did not violate the rule against hearsay, as the interpreter acted as Defendant’s agent under the circumstances of this case; (3) Defendant’s unpreserved confrontation claim was unavailing; (4) the evidence was sufficient to establish Defendant’s impairment; and (5) there was no prejudicial error in the jury instructions. View "Commonwealth v. Adonsoto" on Justia Law

Defendants in these two criminal cases were charged in the Boston Municipal Court (BMC) with a number of felonies. The BMC judges scheduled probable cause hearings for Defendants to determine whether there was sufficient evidence to bind them over to the Superior Court for trial and ordered the Commonwealth to provide Defendants with discovery in advance of those hearings. The Commonwealth objected to the discovery orders, arguing that the BMC and the District Court Department are not explicitly authorized to order discovery in preparation for probable cause hearings. The Supreme Judicial Court affirmed, holding (1) judges of the BMC may, in their discretion, order preheating discovery; and (2) the judges in this case did not abuse their discretion by issuing the discovery orders. View "Commonwealth v. Teixeira" on Justia Law

Two individuals (“the Sureties”) acted as sureties for Defendant and posted bail on his behalf. The Sureties filed a motion for return of bail on the basis that Defendant could not appear for a hearing because he was in federal custody on an immigration and customs enforcement detainer. The motion was denied. After Defendant failed to appear for the hearing, the judge ordered the bail forfeited. The Sureties filed a petition pursuant to Mass. Gen. Laws ch. 211, 3 in the county court asking the court to order return of bail. A single justice denied the petition. The Supreme Judicial Court affirmed, holding that this case did not present the type of exceptional circumstance that requires the exercise of the Court’s extraordinary power of general superintendence pursuant to Mass. Gen. Laws ch. 211, 3. View "Commonwealth v. Baratieri" on Justia Law

In 1993, Defendant was convicted of first degree murder. Defendant’s convictions were affirmed on appeal. After unsuccessfully filing numerous postconviction petitions, Defendant filed in the county court a petition in the nature of mandamus pursuant to Mass. Gen. Laws ch. 249, 5. A single justice denied the petition, concluding that mandamus relief was not appropriate because Defendant had another adequate remedy. Defendant filed a notice of appeal. The Supreme Judicial Court affirmed, holding that, regardless of whether the Court considered the petition pursuant to Mass. Gen. Laws ch. 249, 5 or Mass. Gen. Laws ch. 278, 33E, Defendant was not entitled to relief. View "Vinnie v. Commonwealth" on Justia Law

Petitioner was the defendant in a summary process action in the Housing Court. In 1993, the Appeals Court affirmed. In the years since then, Petitioner repeatedly sought to challenge the foreclosure that led to the summary process action, without success. In 2015, Petitioner filed a motion seeking to vacate the Appeals Court’s 1993 decision. The Appeals Court denied relief. Petitioner subsequently filed a petition pursuant to Mass. Gen. Laws ch. 211, 3 in the county court. A single justice denied the petition. The Supreme Judicial Court affirmed, holding (1) Petitioner failed to prosecute her appeal, and therefore, her appeal could be dismissed on this basis alone; and (2) Petitioner’s claims failed on the merits. View "Eresian v. Merrill Lynch Credit Corp." on Justia Law

After a jury trial, Defendant was found guilty of murder in the first degree and armed robbery. The Supreme Court affirmed. This appeal concerned Defendant’s second motion for a new trial based on newly discovered evidence. The superior court judge allowed the motion for a new trial, ruling that the newly discovered evidence was material, credible, and would have been a real factor in the jury’s deliberations such that this was a case where justice had not been done. The Supreme Judicial Court affirmed, holding that the motion judge did not abuse her discretion in ruling that the newly discovered evidence warranted a new trial. View "Commonwealth v. Ellis" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on a theory of deliberate premeditation. Defendant appealed his conviction and also sought relief under Mass. Gen. Laws ch. 278, 33E asking that his sentence be revised. The Supreme Judicial Court affirmed, holding (1) the trial judge did not err in not allowing the admission of testimony by an expert on eyewitness identification or in allowing the admission of testimony concerning a stocking cap that was seized from a vehicle Defendant was driving several months after the shooting; and (2) there was no reason to exercise the Court’s authority to grant extraordinary relief, but because Defendant’s pending motion to revise and revoke his sentence was timely filed but has not been acted upon, the matter is remanded to the superior court for consideration of the motion. View "Commonwealth v. Snyder" on Justia Law

After a second trial, a jury found Defendant guilty of two counts of murder in the first degree. Defendant later filed a motion for a new trial on the basis of new DNA evidence. The motion judge denied the motion without a hearing. Defendant filed a gatekeeper petition pursuant to Mass. Gen. Laws ch. 278, 33E, and was granted leave to appeal the denial of the motion to the full court. The Supreme Judicial Court vacated the order denying the motion and remanded for further findings. After a nonevidentiary hearing, the motion judge again denied Defendant’s motion for a new trial. Defendant filed a notice of appeal and a petition in the county court to reinstate his appeal in the full court. A single justice treated Defendant’s petition to reinstate his appeal as a second gatekeeper petition and denied the petition. Defendant then filed a motion in the full court to reinstate his appeal. The Supreme Judicial Court affirmed the order denying Defendant’s motion for a new trial, holding (1) the reinstatement of Defendant’s appeal was appropriate; and (2) the motion judge did not abuse his discretion in denying Defendant’s motion for a new trial. View "Commonwealth v. DiBenedetto" on Justia Law

Limoliner Inc., which owned and operated a fleet of luxury motor coaches, hired Dattco, Inc. to perform repair work on one of those vehicles. While Dattco recorded most of those requests in writing, Dattco neglected to write down Limoliner’s verbal request to repair one of the vehicle’s important electrical components. When Dattco failed to make any repairs to that component, Limoliner commenced this action, alleging, inter alia, that Dattco violated Mass. Gen. Laws ch. 93A, 2(a), as interpreted by 940 Code Mass. Regs. 5.05(2), by failing to record Limoliner’s request in writing. Dattco removed the case to federal court on the basis of diversity jurisdiction. Following a jury-waived trial, a magistrate judge found for Dattco on Limoliner’s regulatory claim under 940 Code Mass. Regs. 5.05, concluding that the provision at issue applies only to consumer transactions and not to transactions where the customer is another business. Limoliner appealed, and the United States Court of Appeals for the First Circuit certified a question regarding the issue to the Supreme Court. The Supreme Court answered that 940 Code Mass. Regs. 5.05 does apply to transactions in which the customer is a business entity. View "Limoliner, Inc. v. Dattco, Inc." on Justia Law