Justia Massachusetts Supreme Court Opinion Summaries

In a case before the Supreme Judicial Court of Massachusetts, the defendant, Elvio Marrero, was convicted of the murder of Pernell Kimplin based on evidence that included bloodstains on Marrero's leather jacket. The bloodstains were used by the prosecution to link Marrero to the crime and to support the testimony of a key witness. However, twenty years after the trial, DNA testing showed that the blood on the jacket did not belong to the victim. Marrero's motion for a new trial, based on these DNA test results, was initially denied by a lower court, but the Supreme Judicial Court disagreed with that decision. The court found that the bloodstains were the strongest piece of physical evidence linking Marrero to the murder, and were used by the prosecution to corroborate the testimony of a key witness with credibility issues. As such, the court held that the bloodstains on the jacket likely played a significant role in the jury's deliberations. The court concluded that, had the new DNA test results been available at the time of the trial and the prosecution had been unable to connect the bloodstains to the murder, there is a substantial risk that the outcome of the trial would have been different. Therefore, the court vacated Marrero's conviction and remanded the case for a new trial. View "Commonwealth v. Marrero" on Justia Law

In this Massachusetts case, the defendant, Nyasani Watt, was convicted of first-degree murder and related offenses. After his conviction was affirmed by the Supreme Judicial Court of Massachusetts, he filed a motion for a new trial, alleging that his trial counsel had slept during critical portions of the trial, thus depriving him of his constitutional right to counsel. This motion was denied by a lower court judge without a hearing, and the denial was appealed to the Supreme Judicial Court.The Supreme Judicial Court determined that Watt had presented a new, substantial issue that it could not have considered in its previous review - namely, that his trial counsel had been sleeping during significant parts of the trial.Upon reviewing the evidence, which included affidavits from several people who had observed the trial counsel sleeping, the Court found that the trial counsel did indeed sleep through a significant portion of the trial and possibly during an important aspect of the trial. The Court held that this constituted a constructive deprivation of Watt's right to counsel under Article 12 of the Massachusetts Declaration of Rights.The Court further ruled that this error created a substantial risk of a miscarriage of justice and thus the defendant's convictions were vacated, the verdicts were set aside, and the matter was remanded to the Superior Court for a new trial. View "Commonwealth v. Watt" on Justia Law

In this case, the defendant, Jason Robinson, was convicted of first-degree murder on a joint venture theory of felony-murder, with armed robbery as the predicate offence, in connection with the shooting death of Inaam Yazbek. Robinson appealed his convictions and the denial of his motion for a new trial, claiming insufficient evidence and trial errors.The Supreme Judicial Court of Massachusetts affirmed Robinson's conviction of murder in the first degree and the order denying his motion for a new trial. The court held that there was sufficient evidence to convict Robinson of felony-murder, as there was enough to permit an inference that Robinson knew that his co-defendant was armed during the commission of the armed robbery.The court also found no error in the admission of certain evidence, rejected Robinson's claim that he was prejudiced by being tried with his co-defendant, and found no error in the jury instructions, the exclusion of certain third-party culprit and police failure to investigate evidence, or in the prosecutor's opening statement and closing argument.However, the court ruled that Robinson's sentence of life without the possibility of parole was unconstitutional because he was nineteen years old at the time of the offense. The case was remanded for re-sentencing in line with the court's decision in Commonwealth v. Mattis. View "Commonwealth v. Robinson" on Justia Law

In the case before the Supreme Judicial Court of Massachusetts, the defendant, Sheldon Mattis, was convicted of first degree murder among other charges, and was sentenced to a mandatory term of life in prison without the possibility of parole. At the time of the murder, Mattis was eighteen years old. He appealed his sentence, arguing that it was unconstitutional as applied to him because he was an "emerging adult" (defined in this case as eighteen, nineteen, or twenty years old at the time of the crime), and should be entitled to the same protection as juvenile offenders, who receive a term of life with the possibility of parole.The court considered whether their previous ruling in Diatchenko I, which concluded that sentencing a juvenile to life without parole in any circumstance would violate the Massachusetts Declaration of Rights, should be extended to apply to emerging adults. The court reviewed scientific evidence showing that the brains of emerging adults are not fully mature and are similar to those of juveniles, and also considered the treatment of emerging adults in Massachusetts and elsewhere.The court concluded that a sentence of life without the possibility of parole for emerging adult offenders violates the Massachusetts Declaration of Rights. As a result, the court invalidated the provisions of Massachusetts law that deny the possibility of parole to emerging adults. The court remanded the matter to the lower court for resentencing consistent with the court's opinion. The court also noted that this ruling does not suggest that emerging adults receiving the benefit of resentencing should be paroled once they have served a statutorily designated portion of their sentences. Instead, the parole board should evaluate the circumstances surrounding the commission of the crime, including the age of the offender, together with all relevant information pertaining to the offender's character and actions during the intervening years since conviction. View "Commonwealth v. Mattis" on Justia Law

In this case, several residents of the town of Norwell, Massachusetts filed a lawsuit to compel the town's select board to transfer municipal land to the town's conservation commission. The select board had previously designated the land for the development of affordable housing. The main issue on appeal was whether the land was "held by a city or town . . . for a specific purpose" under Massachusetts General Laws Chapter 40, Section 15A. The Supreme Judicial Court of Massachusetts affirmed the Land Court's grant of summary judgment in favor of the select board. The Supreme Judicial Court held that town-owned land is held for a specific municipal purpose under Massachusetts General Laws Chapter 40, Section 15A, where the totality of the circumstances indicates a clear and unequivocal intent by the town to hold the land for such purpose. Applying this totality of the circumstances test, the court found no material dispute of fact regarding the town's intent to dedicate the municipal land at issue for the purpose of affordable housing. Therefore, the court concluded that the allowance of summary judgment for the select board was correct. View "Carroll v. Select Board of Norwell" on Justia Law

In the case at hand, the plaintiff, a civilly committed sexually dangerous person, petitioned the Department of Correction (DOC) for medical parole due to his deteriorating health conditions. The DOC denied his petition based on their policy that civilly committed individuals are ineligible for medical parole under G. L. c. 127, § 119A. The plaintiff sought review of this denial, arguing that his due process rights had been violated. A Superior Court judge allowed his motion for judgment on the pleadings and ordered the DOC to conduct a hearing on the plaintiff's medical parole petition.However, the Supreme Judicial Court of Massachusetts reversed the judge's order. The court held that the medical parole statute applies only to committed offenders serving a criminal sentence, not to civilly committed sexually dangerous persons. It further held that sexually dangerous persons may seek release due to terminal illness or physical or mental incapacity under G. L. c. 123A, § 9, and denying them an additional avenue for relief by means of the medical parole statute does not offend substantive due process. The Court concluded that the plaintiff's due process rights were not violated by the DOC's policy that precludes civilly committed sexually dangerous persons from eligibility for medical parole. View "Murphy v. Commissioner of Correction" on Justia Law

In the case concerning the estate of Frances R. Mason, the Supreme Judicial Court of Massachusetts ruled on two key issues. First, it considered whether the Massachusetts Medicaid program, MassHealth, could enforce a lien (known as a TEFRA lien) against a member's property after the member's death. The Court concluded that, under Massachusetts law, MassHealth can only enforce such a lien if the property is sold during the member's lifetime. Therefore, MassHealth could not enforce its lien against Mason's property, which was not sold until after her death. This ruling is a restriction on MassHealth's ability to recover Medicaid benefits paid.Second, the Court addressed the timing of MassHealth's claim for recovery of Medicaid benefits paid on Mason's behalf. The Court concluded that the three-year statute of repose of the Massachusetts Uniform Probate Code (MUPC) does not apply retroactively to bar MassHealth's claim against the estate of a member who died prior to the effective date of the MUPC. Accordingly, MassHealth's claim against Mason's estate, which was filed nearly nine years after her death, was not barred by the MUPC's three-year statute of repose.The facts of the case were as follows: Frances R. Mason was a recipient of Medicaid benefits from MassHealth. From January to August 2008, MassHealth paid for her care in a residential nursing facility. In May 2008, MassHealth imposed a TEFRA lien against Mason's home, as she was expected to be permanently institutionalized in the facility. Mason died in August 2008 without the property having been sold. MassHealth filed a claim to recover the Medicaid benefits paid for Mason's care in August 2018, after the executor of Mason's will had opened formal probate proceedings in June 2017.The disposition by the Court was to affirm the order of the Probate and Family Court judge insofar as it struck MassHealth's lien against Mason's home, and to reverse the order insofar as it dismissed MassHealth's claim against her estate. The case was remanded for further proceedings consistent with the Court's opinion. View "In re Estate of Mason" on Justia Law

The case pertains to an appeal by plaintiff William J. Papp, III, against the decision of a single justice of the Supreme Judicial Court denying his request for declaratory relief, a stay of eviction, and relief in the nature of certiorari in relation to a housing dispute. The dispute centered around Papp's objection to the transfer of his case against the defendant landlord from the Superior Court to the Central Division of the Housing Court Department, which he alleged was in violation of G. L. c. 185C, § 20 and deprived him of due process.The Supreme Judicial Court upheld the single justice's decision, affirming that Papp had failed to adequately demonstrate that other remedies were not available to him. The court noted that Papp could have sought interlocutory review of the transfer order from a single justice of the Appeals Court, as per G. L. c. 231, § 118, first par. Additionally, he could have appealed the transfer order as part of an appeal from the final judgment of the Housing Court. Therefore, since Papp could not establish the absence or inadequacy of other remedies, the single justice had not erred or abused her discretion in denying Papp's claims for relief. View "Papp v. Westborough Gardens LLC" on Justia Law

In the case at hand, the defendant, Joshua Hart, and his girlfriend, Brittany Smith, entered the home of an elderly couple, Thomas Harty and his wife, Joanna Fisher, intending to steal their car and money. The couple ended up fatally attacking both Harty and Fisher, and then fled the state in the victims' vehicle. Hart was convicted on two counts of first-degree murder, and he appealed on several grounds.Hart argued that his confession to law enforcement was involuntary and should have been suppressed, but the Supreme Judicial Court of Massachusetts disagreed. The court found that Hart's confession was voluntary based on the circumstances of the interrogation, his experience with the criminal justice system, and his own actions and statements during the interrogation.Hart also argued that the trial should have been moved to another venue due to pretrial publicity. The court disagreed, stating that the defendant did not provide sufficient evidence to demonstrate that the pretrial publicity caused either presumptive or actual prejudice. The court found that less than 20% of potential jurors were excused due to pretrial publicity, and the judge took extensive steps to protect Hart's right to a fair trial.Hart further contended that a statement made by the deceased victim, Fisher, to her nurse, which was relayed to the jury through the nurse's testimony, should have been excluded from evidence as it was hearsay and violated his right to confront witnesses. The court determined that Fisher's statements were non-testimonial and thus did not violate the confrontation clause. The court also found that even if Fisher's statements were admitted in error, there was no prejudice because the Commonwealth presented other compelling evidence of the facts relayed in Fisher's statements.Finally, Hart argued that his sentences of life without the possibility of parole constituted cruel or unusual punishment because he was under 25 years old at the time of the crimes. The court rejected this argument, finding no reason to extend the prohibition of life sentences without parole for juveniles to individuals under the age of 25.Accordingly, the court affirmed Hart's convictions. View "Commonwealth v. Hart" on Justia Law

In a case before the Supreme Judicial Court, the Attorney General of Massachusetts initiated a civil action in the Superior Court alleging housing discrimination by the defendant, Mark Davidson, on behalf of two complainants. The defendant transferred the case to the Housing Court, after which the Attorney General unsuccessfully sought to have the matter transferred back to the Superior Court, arguing that the Housing Court lacked jurisdiction over a discrimination claim in this procedural posture. The complainants had initially filed an administrative complaint with the Massachusetts Commission Against Discrimination, alleging that the defendant had terminated their lease upon learning that one of the complainants was pregnant, allegedly to avoid having to comply with the lead containment or abatement statute. The defendant chose to have the matter heard in court rather than by the commission.The Supreme Judicial Court held that, based on the language of G. L. c. 151B, § 5, the Superior Court is the proper court for actions such as this one, and that the Housing Court lacks jurisdiction. The court reasoned that the language of § 5 unambiguously indicates that the Superior Court is the proper court for such actions. The court also noted that the Legislature's use of the word "shall" suggests a command to commence the action in the Superior Court, and not elsewhere, and the phrase "commence and maintain" is a clear directive that such actions brought by the Attorney General, once initiated, are to remain in the Superior Court. Therefore, the order of the single justice of the Appeals Court was affirmed, and the stay of any proceedings in the Superior Court was vacated. The case must be returned to the Superior Court. View "Commonwealth v. Davidson" on Justia Law