Justia Massachusetts Supreme Court Opinion Summaries

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

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

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

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

Plaintiff engaged Defendants, a law firm and three individual attorneys, to represent him in connection with the prosecution of patents for Plaintiff’s inventions for a new screwless eyeglasses. After learning that Defendants had been simultaneously representing another client that competed with Plaintiff in the screwless eyeglass market, Plaintiff commenced this action alleging harm resulting Defendants’ failure to disclose the alleged conflict of interest. The trial judge dismissed Plaintiff’s complaint for failure to state a claim. The Supreme Judicial Court affirmed, holding (1) the simultaneous representation by a law firm in the prosecution of patents for two clients competing in the same technology area for similar inventions is not a per se violation of the Massachusetts Rules of Professional Conduct; and (2) based on the facts alleged in his complaint, Plaintiff failed to state a claim for relief. View "Maling v. Finnegan, Henderson, Farabow, Garrett & Dunner, LLP" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on theories of deliberate premeditation, extreme atrocity or cruelty, and felony-murder. The Supreme Judicial Court affirmed Defendant’s convictions and declined to grant relief pursuant to Mass. Gen. Laws ch. 278, 33E, holding (1) the trial judge did not err in admitting medical records and related testimony and by instructing the jury on consciousness of guilt; (2) the trial judge did not err in admitting expert testimony concerning the statistical significance of DNA evidence; (3) the trial judge did not err by admitting the victim’s T-shirt into evidence, despite a purported discovery violation by the Commonwealth; (4) the prosecutor did not commit misconduct during her opening statement or her closing argument; and (5) the trial judge properly denied Defendant’s motion for required findings of not guilty. View "Commonwealth v. Cole" on Justia Law

Petitioner was convicted of four counts of violating an abuse prevention order. Petitioner’s direct appeal was entered in the Appeals Court and was pending there when he filed a pleading in the county court entitled “Petition to Remand Sentence for Resentencing.” In the petition, Petitioner asserted that his sentences were unduly harsh and that his trial counsel provided ineffective assistance. A single justice denied the petition without a hearing. The Supreme Judicial Court affirmed, holding that a defendant is not entitled to the extraordinary intervention of the Supreme Judicial Court to vacate or change a sentence that is legal but that the defendant feels is too harsh. View "Souza v. Commonwealth" on Justia Law

Plaintiff was found guilty of indecent assault and battery on a child under fourteen. While Plaintiff was still incarcerated, the Sex Offender Registry Board (SORB) recommended that Plaintiff be classified as a level three sex offender. Plaintiff challenged the recommendation. A SORB hearing officer determined by a preponderance of the evidence that Plaintiff was appropriately classified as a level two offender. The superior court affirmed the level two classification. At issue before the Supreme Judicial Court was the standard of proof that the SORB must satisfy in order to classify a convicted sex offender under the provisions of the sex offender registry law. The Supreme Judicial Court vacated the decision of the superior court affirming SORB’s classification of Plaintiff as a level two sex offender, holding that due process requires that a sex offender’s risk level be proved by clear and convincing evidence. Remanded for entry of an order to SORB to conduct an evidentiary hearing de novo under the heightened standard. View "Doe v. Sex Offender Registry Board" on Justia Law

In the course of their divorce proceedings, Husband and Wife signed a stipulation that they would sell the marital home. The parties were unable to agree on the details, and a judge in the Probate and Family Court appointed a special master to sell the home and to oversee the removal of personal property from it. Husband filed a petition with a single justice of the Appeals Court pursuant to Mass. Gen. Laws ch. 231, 118 seeking relief from the order appointing the special master, asserting that he was against the sale of the home. The Appeals Court justice denied the petition. Husband then filed the instant Mass. Gen. Laws ch. 211, 3 petition. A single justice denied relief. The Supreme Judicial Court affirmed, holding that relief was properly denied in this case. View "Koll v. Edelstein" on Justia Law

A petition for Defendant’s civil commitment as a sexually dangerous person was pending in the superior court. Defendant assented to a finding of probable cause and was temporarily committed for examination and diagnosis by two qualified examiners. The examiners submitted their reports, and the Commonwealth petitioned for trial. Defendant petitioned for relief under Mass. Gen. Laws ch. 211, 3 from the trial judge’s denial of Defendant’s motion in limine to preclude the Commonwealth from calling certain witnesses. A single justice of the Supreme Judicial Court denied the petition. The Supreme Judicial Court affirmed, holding that because Defendant had alternative remedies available to him, the single justice did not err by denying extraordinary relief. View "Chin v. Commonwealth" on Justia Law