Justia Massachusetts Supreme Court Opinion Summaries

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

EventMonitor, Inc. terminated the employment of Anthony Leness, characterizing the termination as “without cause.” After discovering that Leness had copies the data on a company laptop computer EventMonitor retroactively characterized the termination as having been for cause and stopped paying Leness any severance payments. EventMonitor filed suit against Leness, alleging breach of contract, breach of the covenant of good faith and fair dealing, and breach of fiduciary duty. Leness counterclaimed for breach of contract, breach of the covenant of good faith and fair dealing, and violations of the Wage Act. A superior court judge entered judgment for Leness on EventMonitor’s claims and Leness’s counterclaims, finding that Leness had not engaged in defalcation of EventMonitor’s assets and had not committed a material breach of the employment contract, and thus that his termination could not have been for cause. The Supreme Judicial Court affirmed, holding (1) the trial judge correctly found that Leness did not commit a material breach of the employment contract and did not engage in defalcation of company assets, and therefore, Leness committed no act giving rise to a termination for cause; and (2) the trial judge correctly concluded that Leness was entitled to severance payments under the terms of the contract. View "EventMonitor, Inc. v. Leness" on Justia Law

Defendant was arraigned in the municipal court on drug-related and firearm-related charges. The court gave Defendant the bail revocation warning pursuant to Mass. Gen. Laws ch. 276, 58 and released him on personal recognizance. Defendant subsequently failed to appear at a pretrial hearing and was found to be in default. Thereafter, Defendant was charged with a new crime. At his arraignment on the new charge, the court denied the Commonwealth’s motion to revoke Defendant’s bail, concluding that he was not subject to bail revocation because he had defaulted in the prior matter, was no longer “on release,” and therefore did not commit the new crime during his period of release. The Supreme Judicial Court remanded the case with directions to vacate the lower court’s ruling for the reasons set forth in Commonwealth v. Morales, also decided today, which held that a defendant on release pursuant to Mass. Gen. Laws ch. 276, 58, who defaults for failing to appear and is subsequently charged with committing a new crime, is subject to having his bail revoked. View "Commonwealth v. Jaiman" on Justia Law

Defendant was arraigned in the district court on criminal charges in four separate matters. The court gave defendant the bail revocation warning pursuant to Mass. Gen. Laws ch. 276, 58 and released him on personal recognizance. Defendant failed to appear at a subsequent hearing and was found in default. Thereafter, Defendant was arraigned on a new charge. At his arraignment, the Commonwealth moved to revoke Defendant’s bail in the four criminal matters. The district court denied the motion, concluding that Defendant was no longer subject to bail revocation because he had defaulted in the prior matters, was thus no longer “on release,” and therefore did not commit the new crime during the period of release. The Supreme Judicial Court remanded the case with directions to vacate the lower court’s ruling for the reasons set forth in Commonwealth v. Morales, also decided today, which held that a defendant on release pursuant to Mass. Gen. Laws ch. 276, 58, who defaults for failing to appear and is subsequently charged with committing a new crime, is subject to having his bail revoked. View "Commonwealth v. Fontanez" on Justia Law

Defendant was arraigned in the municipal court on a larceny charge. The court gave defendant the bail revocation warning pursuant to Mass. Gen. Laws ch. 276, 58 and released him on personal recognizance. Defendant failed to appear at a subsequent hearing and was found in default. Defendant was subsequently charged with committing assault and battery of a family or household member. At his arraignment on the new charge, the Commonwealth moved to revoke Defendant’s bail or recognizance in the larceny matter. The municipal court judge denied the motion, concluding that Defendant was no longer subject to bail revocation because he defaulted in the prior larceny matter and, therefore, did not commit the new crime during the period of release. The Supreme Judicial Court remanded the case with directions to vacate the lower court’s ruling, holding that a defendant on release pursuant to Mass. Gen. Laws ch. 276, 58, who defaults for failing to appear and is subsequently charged with committing a new crime, is subject to having his bail revoked. View "Commonwealth v. Morales" on Justia Law

Defendant was investigated for, but not indicted for, a 1974 murder. More than twenty-five years later, DNA analysis of tissue taken from under the fingernails of the victim led to Defendant’s indictment for the murder. In 2012, Defendant was convicted of murder in the first degree on the theory of extreme atrocity or cruelty. Just before Defendant filed his appellate brief with the Supreme Judicial Court, he filed a motion to stay the execution of his sentence. A single justice of the Supreme Judicial Court denied the motion. The Supreme Judicial Court affirmed, holding (1) the trial court erred in denying Defendant’s motion to suppress evidence of a paper towel that the police seized from Defendant’s vehicle, but the error was harmless beyond a reasonable doubt; (2) the trial judge did not err in denying Defendant’s pretrial motion to dismiss the murder indictment on the ground that the Commonwealth recklessly or negligently delayed indicting him for thirty-two years, as Defendant failed to show that he was prejudiced by the preindictment delay; (3) Defendant was not entitled to relief under Mass. Gen. Laws ch. 278, 33E; and (4) the single justice did not abuse his discretion in denying Defendant’s motion to stay execution of sentence. View "Commonwealth v. Dame" on Justia Law