Justia Massachusetts Supreme Court Opinion Summaries

Defendant was charged with reckless endangerment of a child by walking on railroad tracks with a child. The trial judge dismissed the count of reckless endangerment, concluding (1) the Commonwealth was required to establish that Defendant was actually aware of the substantial risk of serious bodily injury to which he exposed his child, and (2) sufficient evidence was not presented in the application for the criminal complaint to establish probable cause to believe Defendant had the requisite mental state. The Supreme Court vacated the order of dismissal, holding (1) the trial judge correctly stated the law; and (2) the probable cause requirement was satisfied in this case. View "Commonwealth v. Coggeshall" on Justia Law

Defendant was convicted of armed robbery while masked, kidnapping for purposes of extortion, and armed assault with intent to murder. The Appeals Court affirmed the convictions. Defendant appealed, arguing that the trial court erred in denying his motion to suppress his cellular telephone records. Specifically, Defendant contended that the government failed to comply with Mass. Gen. Laws ch. 271, 17B, as then in effect, in obtaining his telephone records. The Supreme Judicial Court affirmed, holding that Mass. Gen. Laws ch. 271, 17B, as then in effect, did not preclude the government from obtaining the records at issue in this case, and therefore, Defendant’s motion to suppress the records was correctly denied. View "Commonwealth v. Chamberlin" on Justia Law

These cases were appeals of consolidated care and protection petitions concerning six children. The biological mother of the six children, the biological father of the two oldest children, and four of the children appealed from the provisions of decrees of the juvenile court denying parental visitation after termination of the parental rights of the mother, father, and the biological father of the four younger children. The Supreme Judicial Court affirmed the juvenile court judge’s orders denying posttermination or postadoption parental visitation, holding that there was no error in the judge’s decrees in this case. View "In re Adoption of Douglas" on Justia Law

Appellant pleaded guilty to several crimes in connection with an arrest for attempted burglary and other offenses. Appellant moved to vacate two of his convictions of attempted armed burglary and his conviction of possessing a burglarious tool or implement pursuant to Mass. R. Crim. P. 30(a), asserting (1) the convictions of attempted burglary were duplicative, and (2) his conviction for possessing a burglarious instrument should be vacated because the indictment failed to state a crime. The superior court judge denied the motion. The Supreme Judicial Court affirmed in part and reversed in part the denial of Appellant’s motion for postconviction relief, holding (1) Appellant’s multiple convictions and punishments for attempted armed burglary were for separate attempts, and therefore, his multiple convictions and punishments did not violate double jeopardy; but (2) the indictment charging possession of a burglarious tool or implement failed to allege a crime, and therefore, Appellant’s conviction must be vacated. View "Commonwealth v. Dykens" on Justia Law

Two employees were injured in the course of their employment, collected workers’ compensation benefits and then reached settlement agreements with third parties including damages for their pain and suffering. The same insurer insured by employers and sought reimbursement from the employees’ recoveries. In one employee’s case, the superior court judge rejected a settlement agreement providing that the insurer would not have a lien on the damages for pain and suffering. In the second employee’s case, a superior court judge approved a settlement agreement similar to the agreement rejected by the judge in the first employee’s case. The Appeals Court determined that the employees’ awards for pain and suffering were exempt from the insurer’s liens. The Supreme Judicial Court combined the two cases for argument and held that an insurer’s lien does not extend to damages allocated to an employee’s pain and suffering. View "DiCarlo v. Suffolk Constr. Co., Inc. v. Angelini Plastering, Inc." on Justia Law

Defendant was convicted of robbery while armed and masked and attempted robbery. On appeal, Defendant argued, inter alia, that the judge erred in denying his motion for a new trial, which alleged that trial counsel had provided ineffective assistance for failing to file a motion to suppress statements Defendant made to police more than six hours after his arrest, in violation of the safe harbor rule as established in Commonwealth v. Rosario. The Supreme Court affirmed, holding that the trial judge did not err by (1) denying Defendant’s motion for a required finding of not guilty; (2) denying Defendant’s motion for a new trial because volunteered, unsolicited statements made six hours after arrest and before presentment do not require suppression; and (3) denying Defendant’s motion for postconviction discovery. View "Commonwealth v. McWilliams" on Justia Law

Defendant was indicted on seven charges, including armed assault in a dwelling and breaking and entering in the daytime. Defendant moved to suppress the victim’s out-of-court and in-court identifications of Defendant as the intruder he had struggled with in his home. The motion judge, applying the common-law principles of fairness in Commonwealth v. Jones, allowed the motion to suppress, concluding that, through no fault of the police, the identifications were “impermissibly tainted by the suggestive circumstances.” The Supreme Court affirmed, holding that the motion judge did not abuse his discretion in allowing the motion to suppress the identifications. View "Commonwealth v. Johnson" on Justia Law

Plaintiffs, who owned property abutting a proposed development, filed an appeal in the Housing Court from the decision of the planning board of Greenfield granting a special permit in favor of the developer to construct the project. The appeals court held that Mass. Gen. Laws ch. 185, 3A deprived the Housing Court of subject matter jurisdiction to hear major development permit appeals. At issue before the Supreme Judicial Court was whether, by enacting Mass. Gen. Laws ch. 185, 3A, the legislature intended to grant exclusive subject matter jurisdiction to the permit session of the Land Court and to the Superior Court to hear a certain subset of major development permit appeals. The Supreme Judicial Court remanded the case to the Housing Court, holding (1) the legislature intended that major development permit appeals should be adjudicated only in the permit session of the Land Court or in the Superior court; and (2) in this case, where the permit appeal was timely filed in the Housing Court, the appropriate remedy is to transfer the case to a court with jurisdiction rather than dismiss the case for lack of subject matter jurisdiction. View "Skawski v. Greenfield Investors Prop. Dev. LLC" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on theories of deliberate premeditation and extreme atrocity or cruelty and of armed assault with intent to murder. The Supreme Judicial court affirmed Defendant’s convictions but vacated the trial court order denying Defendant’s first motion for a new trial, holding (1) the trial court did not err in admitting evidence of the decedent’s out-of-court statement about who had shot him; (2) the performance of Defendant’s first counsel was ineffective, and it is necessary to vacate the denial of Defendant’s first motion for a new trial and to remand the case for an evidentiary hearing to determine whether Defendant was prejudiced by his counsel’s deficient performance; and (3) any impropriety on the part of the prosecutor did not create a substantial likelihood of a miscarriage of justice. View "Commonwealth v. Celester" on Justia Law

Abinel Zenon was charged with assault and battery, among other offenses. Zenon sought certain third-party records to support his claim that the alleged victim was, in fact, the first aggressor. A judge of the district court issued a protective order concerning these records, apparently following the protocol set forth in Commonwealth v. Dwyer. Zenon subsequently filed various motions for relief from the protective order, but these motions were only partially successful. Thereafter, Zenon filed this petition for relief from a protective order. A single justice of the Supreme Judicial Court denied relief without holding a hearing after treating the petition as one filed pursuant to Mass. Gen. Laws ch. 211, 3. The Supreme Judicial Court affirmed, holding that Zenon had an adequate alternative remedy. View "Zenon v. Commonwealth" on Justia Law