Justia Massachusetts Supreme Court Opinion Summaries

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

After a jury trial, Defendant was convicted of operation of a motor vehicle while under the influence of liquor (OUI), possession with intent to distribute a class B substance, and possession with intent to distribute a class B substance in a school zone. The Appeals Court affirmed. On appeal, the Commonwealth conceded that certain testimony was improperly admitted. Defendant, however, did not object to or move to strike the testimony. Defendant appealed, arguing that improperly admitted testimony violated his confrontation rights. The Supreme Judicial Court affirmed, holding (1) under the circumstances of this case, Defendant did not properly preserve his appellate rights; and (2) the error did not create a substantial risk of a miscarriage of justice. View "Commonwealth v. Grady" on Justia Law

Bank of America, N.A., in its capacity as a corporate trustee of several inter vivos trusts, applied for abatement of fiduciary income taxes paid by thirty-four inter vivos trusts. The Commissioner of Revenue denied the applications. The Bank appealed, arguing that, where the Bank was not domiciled in Massachusetts, these trusts did not qualify as “resident inter vivos trusts” and therefore were not subject to fiduciary income tax under Mass. Gen. Laws ch. 62, 10. The Appellate Tax Board upheld the Commissioner’s decision, concluding that the Bank, in its capacity as trustee, was an inhabitant of the Commonwealth within the meaning of Mass. Gen. Laws ch. 62, 1(f) and 10(c). The Supreme Judicial Court affirmed, holding that the Board did not err in ruling that the Bank was subject to the fiduciary income tax imposed by section 10. View "Bank of America, N.A. v. Comm’r of Revenue" on Justia Law

Defendant was convicted of murder in the first degree on theories of deliberate premeditation and extreme atrocity or cruelty. The Supreme Judicial Court affirmed the conviction and declined to exercise its powers under Mass. Gen. Laws ch. 278, 33E, holding (1) the trial judge did not abuse his discretion when he refused to admit evidence of the victim’s prior violence against Defendant’s girl friend; (2) even if the prosecutor’s comments in his closing argument were improper, they did not warrant reversal; and (3) the Court need not address Defendant’s argument that the Court should require the defendant’s state of mind to be considered in determining whether a murder is committed with extreme atrocity or cruelty. View "Commonwealth v. Lopez" on Justia Law

At issue in these two consolidated appeals was an initiative petition that proposed to legalize, regulate, and tax marijuana and products that contain marijuana concentrate. In the first case (Hensley case) Plaintiffs claimed that the Attorney General erred in certifying the petition for inclusion on the ballot under article 48 of the Amendments to the Massachusetts Constitution because it contained two unrelated subjects, because the Attorney General’s summary was not fair, and because the title and one-sentence statements were misleading. In the second case (Allen case) Plaintiffs challenged the title and one-sentence statements but on different grounds from those alleged by the Hensley plaintiffs. The Supreme Judicial Court ordered the Attorney General and Secretary of the Commonwealth to amend the title and statement, holding (1) the Attorney General did not err in certifying the petition for inclusion on the ballot because the petition contains only related subjects and the summary of the petition is fair; but (2) the petition’s title and the one-sentence statement describing the effect of a “yes” vote are misleading, in violation of Mass. Gen. Laws ch. 54, 53. View "Hensley v. Attorney General" on Justia Law

On August 5, 2015, sixteen voters submitted Initiative Petition 15-12 to the Attorney General. The petition (1) sought to end the use of the Common Core State Standards in defining the educational curriculum of publicly funded elementary and secondary students in the Commonwealth, and (2) addressed the standardized testing process used in Massachusetts school districts. The Attorney General certified to the Secretary of the Commonwealth that the petition was in the proper form and met the requirements of article 48, The Initiative, II, section 3 of the Amendments to the Massachusetts Constitution. On January 22, 2016, Plaintiffs filed a complaint seeking to quash the certification of the petition and to enjoin the Secretary from including the substance of the proposed measure on the November, 2016 ballot. The Supreme Judicial Court granted the requested relief, holding that the Attorney General’s certification of Initiative Petition 15-12 did not comply with article 48 because it contained provisions that were not related or mutually dependent. View "Gray v. Attorney General" on Justia Law