Justia Massachusetts Supreme Court Opinion Summaries

After a jury trial, Defendant was found guilty of murder in the first degree on the theory of extreme atrocity or cruelty and four related offenses. The Supreme Judicial Court affirmed Defendant’s convictions and declined to grant relief pursuant to Mass. Gen. Laws ch. 278, 33E, holding that the trial judge did not err by (1) declining to instruct the jury on voluntary manslaughter as a lesser included offense of the murder charge; (2) instructing the jury on the concept of malice in relation to murder under the theory of extreme atrocity or cruelty; (3) allowing the jury to consider evidence that, contrary to Defendant’s argument, was not hearsay; and (4) denying Defendant’s motion for a required finding of not guilty on the two charges relating to one of the victims of Defendant’s non-murder-related crimes. View "Commonwealth v. Spinucci" on Justia Law

Defendants, Jason Estabrook and Adam Bradley, were indicted for murder and related crimes. At issue in this case was the superior court’s denial of Defendants’ motion to suppress historical cellular site location information (CSLI) pertaining to Bradley’s cellular telephone that police officers obtained without a search warrant and then later reobtained pursuant to a warrant. The judge also refused to suppress statements Defendants made to police following the receipt of Bradley’s CSLI. The Supreme Judicial Court affirmed, holding (1) the Commonwealth does not violate a defendant’s reasonable expectation of privacy when it requests up to six hours of historical CSLI without obtaining a search warrant; (2) because the Commonwealth requested two weeks of historical CSLI in this case, a search warrant was required; but (3) many of Defendants’ statements and Bradley’s CSLI were not subject to suppression due to the CSLI that was first obtained unlawfully because (i) Defendants’ statements were not made in response to being confronted by the tainted CSLI, and (ii) the search warrant was supported by probable cause derived from information obtained independently rather than through the tainted CSLI. View "Commonwealth v. Estabrook" on Justia Law

After a trial, Defendant was convicted of murder in the first degree on a theory of deliberate premeditation. Defendant filed a motion for a new trial, which the trial judge denied. Defendant appealed from his conviction and from the denial of his motion for a new trial, claiming that the trial judge erred on the eve of trial by denying Defendant’s motion for disclosure of the identity of an informant who, according to a report prepared by the FBI, had heard that Defendant’s friend, and not the defendant, had shot the victim. The Supreme Judicial Court remanded for further proceedings in connection with Defendant’s motion for disclosure of the informant’s identity but did not now see cause to exercise its authority under Mass. Gen. Laws ch. 278, 33E to reduce the verdict or to order a new trial. View "Commonwealth v. Bonnett" on Justia Law

Defendant was tried and convicted of murder in the first degree based on a theory of felony-murder, with armed home invasion as the predicate felony. While Defendant’s appeal was pending, he filed a motion for postconviction relief seeking a finding of not guilty on the felony-murder conviction or, in the alternative, a new trial on the murder charge. The trial judge granted a new trial, concluding (1) the evidence was sufficient to support a finding that there had been two separate and distinct assaults; but (2) the jury had not been adequately instructed that to convict Defendant of felony-murder based on the armed home invasion, the jurors were required to find two separate and distinct assaults. Defendant appealed, arguing that the evidence was insufficient to support his murder conviction. The Supreme Judicial Court affirmed the judge’s order denying the request for a finding of not guilty on the charge of murder in the first degree, with armed home invasion as the predicate felony, holding that the Commonwealth presented evidence that would warrant a finding that Defendant committed two separate assaults, one to support a conviction of armed home invasion and a separate and distinct assault that constituted the homicide. View "Commonwealth v. Scott" on Justia Law

The town of Randolph bypassed Plaintiff, a police officer with the town, and appointed three candidates with lower scores on the police sergeant’s examination to its three open police sergeant positions. Plaintiff appealed. The Civil Service Commission dismissed the appeal. Plaintiff sought review of the Commission’s decision in the superior court. A superior court judge denied Plaintiff’s motion for reconsideration and entered judgment for the Commission. The Supreme Judicial Court affirmed the superior court’s denial of Plaintiff’s motion for judgment on the pleadings, holding (1) the record did not support the concern that the town’s flawed procedure for selecting candidates reflected a departure from basic merit principles; and (2) there was substantial evidence to support a reasonable justification for the town’s bypass. View "Sherman v. Town of Randolph" on Justia Law

The Town of Hanover decided to bypass Plaintiff, a police officer with the town, and appoint two candidates with lower scores on the police sergeant’s examination to its open police sergeant positions. Plaintiff appealed the town’s decision to the Civil Service Commission, arguing that, pursuant to Mass. Gen. Laws ch. 31, 2(b), where an appointing authority promotes a candidate other than the candidate ranked highest on the certification list, the promotion is not effective until the appointing authority’s statement of reasons for the bypass have been “received by the administrator” and that the administrator may not delegate that function to the town’s appointing authority. The Commission denied the appeal. A superior court judge allowed Plaintiff’s motion for judgment on the pleadings and and remanded the matter to the human resources division (HRD) to decide whether the bypass reasons should be approved. The Supreme Judicial Court vacated the judgment and remanded, holding (1) the administrator may delegate its administrative function to receive statements of reasons supporting bypass promotions, and it was practicable to do so in this case; and (2) the judge erred in remanding the matter to the HRD without conducting his own review of whether the Commission’s determination was supported by substantial evidence. View "Malloch v. Town of Hanover" on Justia Law

During the divorce proceedings of Husband and Wife, the trial judge found that Husband’s alleged abuse of one of the parties’ two minor children had not been proved by a preponderance of the evidence. A judgment of divorce nisi issued, which granted Husband unsupervised parenting time with the children. Wife moved for a stay pending appeal. The probate and family court and a single justice of the Appeals Court denied the motions. Wife subsequently filed this petition pursuant to Mass. Gen. Laws ch. 211, 3 seeking a stay. A single justice of the Supreme Judicial Court denied the petition without a hearing. The Supreme Judicial Court affirmed the single justice’s denial of a stay, holding that the single justice did not err or abuse his discretion by denying a stay pending appeal. View "C.E. v. J.E." on Justia Law

A police officer stopped a vehicle based on the officer’s detection of an odor of burnt marijuana coming from the vehicle. During the course of the stop, police discovered sixty Percocet pills. Defendant, a passenger in the vehicle at the time of the stop, was charged with several drug-related offenses all in connection with the pills. Defendant moved to suppress evidence of the pills. The motion judge denied the motion to suppress, concluding that the stop was justified. The Supreme Judicial Court reversed, holding that there was at best reasonable suspicion to believe that a civil marijuana infraction was occurring, but not probable cause, and therefore, the stop was impermissible. View "Commonwealth v. Rodriguez" on Justia Law

The plaintiffs in this case owned beachfront lots in the Town of Dennis, and the defendants owned lots located to the south and west of the plaintiffs’ lots. The parties, who were in the same subdivision, disputed access over a private way to the beach that ran between the plaintiffs’ lots. The plaintiffs filed an action to quiet title and for declaratory relief against the defendants. The trial judge determined that the plaintiffs held the fee in the way. The judge then divided the defendants into three groups and determined, as to the first two groups, the defendants held easements over the way, and that the defendants in the third group did not. The Supreme Judicial Court affirmed in part and reversed, holding (1) the plaintiffs did not hold the fee in the way but were easement holders; (2) as to the first and second groups of defendants, the judge correctly determined that the defendants held easements over the way; and (3) the third group of defendants also held easements for access to the waterfront over the way. View "Hickey v. Pathways Ass’n, Inc." on Justia Law

After a jury trial, Defendant was convicted of rape and furnishing alcohol to a minor. The Supreme Judicial Court vacated Defendant’s convictions and remanded for a new trial, holding (1) the trial judge erred in permitting an expert witness who was not present when the victim’s “rape kit” examination was performed to testify about how the various swabs she tested had been collected, and the error was prejudicial; and (2) the trial judge erred in closing the rape shield hearing to determine the admissibility of evidence relating to the victim’s prior sexual contact with the individual to whom the victim first reported the alleged rape without conducting the four-prong framework required for court room closures under the United States Supreme Court’s decision in Waller v. Georgia. View "Commonwealth v. Jones" on Justia Law