Justia Massachusetts Supreme Court Opinion Summaries

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Regency Transportation, Inc. is a Massachusetts S corporation that carries and delivers goods throughout the eastern United States. In 2010, the Commissioner of Revenue imposed a use tax on the full purchase price of each tractor and trailer in Regency’s fleet. The Commissioner subsequently denied Regency’s request for full abatement of the assessment. Regency appealed, arguing that the Commonwealth’s imposition of a use tax on vehicles engaged in interstate commerce violates the commerce and equal protection clauses of the Federal and State Constitutions. The Appellate Tax Board concluded that the motor vehicle use tax does not violate either the commerce or equal protection clauses. The Supreme Judicial Court affirmed, holding that an unapportioned use tax imposed on Regency’s interstate fleet of vehicles does not violate the commerce clause of the Federal Constitution. View "Regency Transp., Inc. v. Comm’r of Revenue" on Justia Law

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Defendant sought an order requiring the Commonwealth to disclose whether a witness cooperating against him had previously served as a confidential informant or cooperating witness. The superior court judge granted Defendant’s request, concluding that prior cooperation by the witness could be relevant to demonstrating the witness’s bias or hope of benefit or reward. The Commonwealth filed a petition for relief pursuant to Mass. Gen. Laws ch. 211, 3. A single justice of the Supreme Judicial Court affirmed. The Supreme Judicial Court affirmed, holding that the Commonwealth failed to demonstrate the presence of exceptional circumstances to warrant the Court’s review of this interlocutory matter. View "Commonwealth v. Forlizzi" on Justia Law

Posted in: Criminal Law
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Defendant was stopped by a state police trooper, who was prompted by the receipt of an anonymous 911 call concerning an apparent drunk driver. After a bench trial, Defendant was convicted of operating a motor vehicle while under the influence of alcohol. Defendant appealed, arguing that the trial court erred in denying his motion to suppress the evidence obtained during the warrantless stop of his vehicle because the stop was neither supported by reasonable suspicion nor made pursuant to an ongoing emergency. The appeals court affirmed the denial of Defendant’s motion to suppress, concluding that the information bore sufficient indicia of reliability, and therefore, the trooper could rely on the information in establishing reasonable suspicion to conduct an investigatory stop. The Supreme Judicial Court affirmed, holding that the information gathered from the anonymous call, corroborated by other information, was sufficiently reliable to warrant a finding that the trooper had reasonable suspicion to stop Defendant’s vehicle. View "Commonwealth v. Depiero" on Justia Law

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Plaintiffs, a married couple, filed an application with the Department of Children and Families for a license that would enable them to become foster and preadoptive parents. The Department denied the application because of Plaintiffs’ use of corporal punishment as a form of discipline in their home. A hearing officer affirmed. Plaintiffs appealed, alleging that the Department’s decision was inconsistent with its regulations, was arbitrary and capricious, and was not supported by substantial evidence. Plaintiffs also argued that the Department’s decision impermissibly infringed on their right to the free exercise of their religion under the Federal and State Constitutions because physical discipline is an integral aspect of their Christian faith. The Supreme Judicial Court affirmed, holding (1) the Department’s decision to deny Plaintiffs’ application was supported by substantial evidence, was not arbitrary or capricious, and was based on a reasonable interpretation of its enabling legislation; and (2) the substantial burden that the Department’s decision imposed on Plaintiffs’ sincerely held religions beliefs was outweighed by the Department’s compelling interest in protecting the welfare of foster children. View "Magazu v. Dep’t of Children and Families" on Justia Law

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Petitioner was the defendant in a criminal case in which he was charged with a single count of criminal harassment. Petitioner filed a motion to dismiss the complaint, alleging that the clerk-magistrate issued the complaint on the basis of perjured testimony at a show cause hearing. A district court judge denied the motion. Petitioner then filed a pleading seeking relief pursuant to Mass. Gen. Laws ch. 211, 3. A single justice of the Supreme Judicial Court denied the petition without a hearing. The full Court affirmed, holding that Petitioner failed to comply with S.J.C. Rule 2:21 in pursuing this appeal, and Petitioner’s claim failed on the merits. View "Afrasiabi v. Commonwealth" on Justia Law

Posted in: Criminal Law
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After a jury trial, Defendant was found guilty of murder in the first degree on the theory of deliberate premeditation. Defendant appealed, asserting, among other claims, that he was entitled to a new trial because he was denied his constitutional right to the effective assistance of counsel for two reasons. The Supreme Judicial Court affirmed Defendant’s convictions and declined to exercise its authority to order a new trial or to reduce the verdict of murder in the first degree, holding (1) counsel’s alleged errors were not likely to have influenced the jury’s conclusion; and (2) Defendant’s claims that various errors were made by the prosecutor and judge were without merit. View "Commonwealth v. Gonzalez" on Justia Law

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After learning that two of the guests from a party at Defendant’s house were ill from ingesting tequila and that Defendant might also be ill, the police entered Defendant’s home to perform a well-being check under the “emergency aid” exception to the constitutional warrant requirement. While there, the police seized two tequila bottles, one of which was found to contain a so-called “date rape” drug. Defendant filed a motion to suppress, which the trial court denied. After a jury trial, Defendant was convicted of rape, drugging for sexual intercourse, and drugging to confine. The Supreme Judicial Court vacated the judgments of conviction, holding (1) the police had objectively reasonable grounds to believe that Defendant may be in need of immediate medical assistance, and therefore, the warrantless entry into Defendant’s home was justified; but (2) the seizure of the evidence was unreasonable because (i) it occurred after Defendant was transported to the hospital and while the police remained in his home without his consent, and (ii) the police seized the evidence for investigative purposes without verifying any demonstrable relationship to the emergency justifying their entry into Defendant’s home. Remanded for a new trial. View "Commonwealth v. Kaeppeler" on Justia Law

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After a jury trial, Defendant was convicted of two counts of armed robbery, two counts of murder in the first degree, and one count each of home invasion, unlawful possession of ammunition, and possessing a firearm without a license. The Supreme Judicial Court affirmed the convictions and declined to exercise its authority pursuant to Mass. Gen. Laws ch. 278, 33E, holding (1) the trial court did not err in denying Defendant’s motion to suppress the firearm used in the armed robbery and murders; and (2) Defendant’s right to due process was not violated by the joinder of his trial with his codefendants and in the joinder of the armed robbery charges and charges relating to the home invasion. View "Commonwealth v. Hernandez" on Justia Law

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Defendant was charged with malicious destruction of property over $250. The charge was based on the allegation that Defendant caused a security gate at his property to strike and damage the complaining witness’s (CW) vehicle. During discovery, Defendant filed a request for mandatory discovery of the CW’s criminal record. The probation department produced the unsealed entries in the CW’s criminal record but withheld the entries sealed pursuant to Mass. Gen. Laws ch. 276, 100A. Thereafter, Defendant filed a motion to compel production of the sealed criminal record. The judge denied the motion. Defendant subsequently filed this petition for review pursuant to Mass. Gen. Laws ch. 211, 3, claiming that mandatory disclosure required by Mass. Gen. Laws ch. 218, 26A and Mass. R. Crim. P. 14(a)(1)D) is not subject to an exception for sealed criminal records and that disclosure was necessary to effect his constitutional right to confrontation of the CW. The Supreme Judicial Court denied relief, holding (1) the mandatory discovery provisions of Mass. Gen. Laws ch. 218, 26A and Rule 14(a)(1)(D) do not apply to criminal records sealed pursuant to Mass. Gen. Laws ch. 276, 100A; and (2) Defendant failed to establish a constitutional right to disclosure for confrontation purposes. View "Wing v. Comm’r of Probation" on Justia Law

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Defendant was convicted on four indictments alleging indecent assault and battery on a person with an intellectual disability in violation of Mass. Gen. Laws ch. 265, 13F. The crimes were alleged to have occurred between on or about January 1, 2008 and on or about September 16, 2011. On the effective date of November 2, 2010, the Legislature amended the statute substituting the term “mentally retarded person” with “person with an intellectual disability.” On appeal from the denial of his postconviction motions, Defendant asserted that the term “intellectual disability” renders Mass. Gen. Laws ch. 265, 13F unconstitutionally vague and that he was convicted under an ex post facto law. The Supreme Judicial Court affirmed, holding (1) Mass. Gen. Laws ch. 265, 13F, as amended, is constitutional; and (2) the convictions do not violate the ex post facto prohibitions of the Massachusetts Constitution or United States Constitution. View "Commonwealth v. St. Louis" on Justia Law