Justia Massachusetts Supreme Court Opinion Summaries

Plaintiff was injured after slipping and falling on a walkway leading into a garden store owned by Defendant. Plaintiff filed a complaint asserting that she tripped on a stone that had traveled from a gravel area near the concrete walking leading into the store to the walkway. Defendant moved for summary judgment, arguing that Plaintiff could not prevail under the traditional theory of premises liability. Plaintiff, in turn, argued that, although she could not prevail under a traditional theory of premises liability, she could prevail by applying a mode of operation analysis. The superior court granted summary judgment in favor of Defendant, concluding that the mode of operation approach was not applicable in these circumstances. The Supreme Judicial Court vacated the judgment in favor of Defendant, holding that the mode of operation analysis was applicable under the circumstances presented here. View "Bowers v. P. Wile's, Inc." on Justia Law

Defendant was convicted of murder in the first degree on a theory of deliberate premeditation in the shooting death of his former wife. The Supreme Judicial Court affirmed the convictions, holding (1) the trial judge did not abuse her discretion in allowing the admission of evidence of prior bad acts; (2) the prosecutor did not commit error during closing arguments; (3) the trial judge did not err in denying Defendant’s motion for a mistrial after learning that three jurors had discussed the case before deliberations began; and (4) the Court declines to exercise its power under Mass. Gen. Laws ch. 278, 33Ea to reduce the verdict of murder in the first degree to a lesser degree of guilt. View "Commonwealth v. Philbrook" on Justia Law

Defendant was indicted for several drug offenses. Defendant filed a motion for issuance of a subpoena seeking certain data he claimed would be relevant to support his claim that he was subjected to selective enforcement and racial profiling. A superior court judge denied the motion. Thereafter, Defendant filed a petition for relief under Mass. Gen. Laws ch. 211, 3. A single justice in the county court denied the petition without a hearing. The Supreme Judicial Court affirmed, holding that the single justice neither erred nor abused his discretion by denying extraordinary relief. View "Martinez v. Commonwealth" on Justia Law

In 2007, Defendant pleaded guilty on indictments charging several drug-related offenses. In 2012, Defendant filed a motion to withdraw his guilty pleas based on the misconduct of Annie Dookhan, a chemist who was employed in the forensic drug laboratory of the William A. Hinton State Laboratory Institute from 2003 until 2012. Prior to the issuance of a ruling on Defendant’s motion, the Supreme Court decided Commonwealth v. Scott, in which the Court articulated a framework for analyzing a defendant’s motion to withdraw a guilty plea in a case involving Dookhan’s malfeasance. In light of Scott, as well as new evidence, Defendant filed supplemental pleadings in 2014 in support of his motion to withdraw his guilty pleas. The superior court denied Defendant’s motion to withdraw his guilty pleas. The Supreme Judicial Court affirmed, holding that Defendant was not entitled to the conclusive presumption established in Scott that egregious government misconduct occurred in his case, and therefore, Defendant’s motion to withdraw his guilty pleas was properly denied. View "Commonwealth v. Resende" on Justia Law

After a trial, Defendant was found guilty of the trafficking and distribution of cocaine. During trial, drug certificates were admitted into evidence that were signed by Annie Dookhan declaring that the substances in question were cocaine and that set forth their weight. Six years after the jury returned their guilty verdicts, Defendant filed a motion for a new trial, alleging that he was entitled to a new trial because of newly discovered evidence arising from Dookhan’s misconduct in conducting drug analyses. The trial judge denied the motion. The Appellate Court affirmed. The Supreme Judicial Court vacated Defendant’s convictions and remanded for a new trial, holding (1) a defendant found guilty at trial who moves for a new trial is entitled to the same conclusive presumption of “egregious government misconduct” that the Court applied in Commonwealth v. Scott to cases where a defendant seeks to withdraw his guilty plea after learning of Dookhan’s misconduct; and (2) the trial court in this case erred in admitting the drug certificates regarding Dookhan’s drug analysis, and the Commonwealth did not meet its burden of proving that the admission of the drug certificates did not influence the jury or had only a slight effect on their verdicts. View "Commonwealth v. Francis" on Justia Law

Defendant was sixteen years old at the time he admitted to committing murder. Defendant made his confession after prolonged questioning by the police and by his mother. Defendant filed a motion to suppress his statements to the police, but the motion was denied. After a jury trial, Defendant was convicted of murder in the first degree on the theory of deliberate premeditation and unlicensed possession of a firearm. Defendant filed a motion for a new trial, alleging that he was denied the effective assistance of counsel. Defendant’s claims were denied, and the denial of his motion was consolidated with his direct appeal. The Supreme Judicial Court affirmed Defendant’s convictions and declined to grant relief under Mass. Gen. Laws ch. 278, 33E, holding (1) the Court declines to expand the rule requiring the corroboration of extrajudicial statements as it applies to juvenile confessions; (2) the trial court did not err by denying Defendant’s motion for a new trial; (3) the trial court did not err by denying Defendant’s motion to suppress on the grounds asserted by Defendant; and (4) the trial court did not err by denying Defendant’s motion for a directed verdict on the firearms charge. View "Commonwealth v. Weaver" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree and assault and battery. The Supreme Judicial Court affirmed Defendant’s convictions and discerned no basis to exercise its authority pursuant to Mass. Gen. Laws ch. 278, 33E, holding (1) the trial judge did not act unreasonably in failing to conduct a voir dire of an inattentive juror; (2) the judge did not abuse his discretion in his evidentiary rulings allowing the admission of numerous autopsy photographs, certain of Defendant’s statements, and the victim’s purse; (3) the judge did not err in giving instructions to the jury in accordance with Commonwealth v. DiGiambattista; and (4) the judge’s instructions on murder in the first degree committed with extreme atrocity or cruelty were not in error. View "Commonwealth v. Alleyne" on Justia Law

After a jury trial, Defendant was convicted of assault and battery on a child causing substantial bodily injury. The prosecution argued that Defendant violently shook a toddler in his care based on medical testimony that the child was diagnosed with three symptoms associated with shaken baby syndrome. At trial, Defendant contended that the child had fallen down the stairs in her home and later fallen off a kitchen stool. Defendant filed a postconviction motion for a new trial, arguing (1) his counsel was ineffective for failing to retain a medical expert to acknowledge the possibility that the child’s injuries could have been caused by an accidental short-distance fall, and (2) new scientific advances on shaken baby syndrome and short falls warranted a new trial. The motion judge denied the motion, and the Appeals Court affirmed. The Supreme Judicial Court reversed, holding that, under the circumstances of this case, Defendant was deprived of a defense due to counsel’s failure to find an appropriate expert to testify that the child’s injuries might have been caused by her accidental falls, thereby creating a substantial risk of a miscarriage of justice. Remanded for a new trial. View "Commonwealth v. Epps" on Justia Law

Defendant was convicted of two counts of indecent assault and battery on a child under fourteen. Defendant was later found to be in violation of his probation. The judge revoked the probation and imposed a term of imprisonment. Defendant engaged in a patter of quarrelsome, confrontational, and hostile conduct toward nine different court-appointed attorneys over the course of the trial and post trial proceeding. On those grounds, the judge ordered the forfeiture of Defendant’s right to counsel. Defendant appealed, arguing that the judge erred in the forfeiture order and the probation revocation hearing. The Appeals Court affirmed. The Supreme Judicial Court vacated the forfeiture order, holding (1) the forfeiture hearing did not meet the procedural due process requirements articulated in Commonwealth v. Means; and (2) Defendant’s conduct was not sufficiently egregious to warrant forfeiture under the guidelines established in Means. View "Commonwealth v. Gibson" on Justia Law

After a jury trial, Defendant was convicted of possession of a class B controlled substance and possession of class B and C controlled substances with intent to distribute. On appeal, Defendant argued that the prosecution’s expert witness, a police officer, impermissibly offered an opinion as to Defendant’s guilt. The Appeals Court affirmed. In so doing, the court concluded that Defendant did not preserve the error and thus reviewed the claim to determine whether a substantial risk of a miscarriage of justice was created rather than to determine whether the error was prejudicial. The Supreme Judicial Court affirmed, holding (1) the error Defendant challenged should be reviewed to determine whether it created a substantial risk of a miscarriage of justice; and (2) the error did not create a substantial risk of a miscarriage of justice. View "Commonwealth v. Almele" on Justia Law