Justia Massachusetts Supreme Court Opinion Summaries

The district court issued a complaint charging Defendant with distribution of heroin and conspiracy to violate the drug laws. Prior to arraignment, Defendant moved to dismiss the complaint. A district court judge denied the motion, ruling that there was probable cause to issue the complaint. Defendant subsequently filed a Mass. Gen. Laws ch. 211, 3 petition seeking relief from this ruling. A single justice of the Supreme Judicial Court denied the petition without a hearing. The Supreme Judicial Court affirmed, holding that the district court’s ruling did not present an exceptional circumstances warranting exercise of the Court’s extraordinary superintendence powers. View "Brea v. Commonwealth" on Justia Law

In 2012, Plaintiff filed an action alleging that Defendant had sexually abused her between 1968 and 1977, when she was a child. Until June 2014, civil actions alleging sexual abuse of a minor were governed by a three-year statute of limitations. See Mass. Gen. Laws ch. 260, 4C. Section 4C was amended effective June 2014 to extend the limitations period to thirty-five years. The superior court in this case dismissed the complaint on statute of limitations grounds. The Supreme Judicial Court vacated the judgment of the superior court, holding (1) under the circumstances of this case, section 4C’s extended statute of limitations applies to Plaintiff’s case; and (2) the retroactive application is constitutional as applied to Defendant. Remanded. View "Sliney v. Previte" on Justia Law

After a jury trial, Defendant was convicted of murder in the second degree on the theory of felony-murder, with armed robbery as the underlying felony. The trial judge allowed Defendant’s motion for a required finding of not guilty on the felony-murder conviction. At issue on appeal was whether a defendant who joins with others to commit an armed robbery may be found guilty of murder on the theory of felony-murder for the killing of his accomplice by someone resisting the armed robbery. The Supreme Judicial Court affirmed the judge’s order allowing Defendant’s motion for a required finding of guilty on the indictment charging felony-murder in the second degree, holding that a defendant cannot be held criminally liable for the death of any person killed by someone resisting the commission of the felony. View "Commonwealth v. Tejeda" on Justia Law

After a trial, Defendant was convicted of murder in the first degree. Defendant appealed. Defendant also filed a motion for a new trial, arguing that she was deprived of the effective assistance of trial counsel. Defendant’s appeal was stayed pending resolution of her motion for a new trial. On the Commonwealth’s motions, the trial judge ordered that trial counsel be summonsed to testify at the hearing on Defendant’s motion and that Defendant provide the Commonwealth with certain discovery. Defendant subsequently filed a petition pursuant to Mass. Gen. Laws ch. 211, 3 seeking relief from these orders. A single justice of the Supreme Judicial Court denied extraordinary relief. The Supreme Judicial Court affirmed, holding that Defendant had an adequate alternative remedy by way of appeal from any adverse ruling on the motion for a new trial. View "Field v. Commonwealth" on Justia Law

After a jury trial, Defendant was convicted on three indictments charging armed robbery with a firearm while masked. Defendant used a BB gun to perpetrate each of the robberies. Defendant appealed, arguing that the evidence was insufficient to support his conviction. The Supreme Judicial Court vacated Defendant’s convictions for armed robbery by means of a firearm, holding that a BB gun does not satisfy the statutory requirement of a “firearm” within the meaning of the armed robbery statute. Remanded to the superior court for entry of judgments of guilt on the lesser included offense of unarmed robbery. View "Commonwealth v. Garrett" on Justia Law

In 2007, Brad Delp, the lead singer of the rock band “Boston,” committed suicide. The Boston Herald, Inc., published three stories regarding Brad’s suicide. The two authors of the newspaper articles relied on information from Brad’s former wife, Micki Delp. Donald Scholz, who founded “Boston,” filed an action for defamation against Micki, arguing that her statements insinuated that Scholz was responsible for Brad’s suicide. Scholz then brought an action for defamation and intentional infliction of emotional distress against the Boston Herald and the two authors (collectively, the Herald) based on the same statements as reported in the three articles. The superior court granted summary judgment for Micki. The appeals court reversed. A different superior court judge allowed the Herald’s motion for summary judgment. The Supreme Judicial Court paired the cases for judgment and held (1) the second motion judge properly granted summary judgment for the Herald, as the newspaper articles and statements contained therein constituted nonactionable opinions based on disclosed nondefamatory facts that did not imply undisclosed defamatory facts and therefore could not form the basis of a claim of defamation; and (2) the first motion judge correctly allowed Micki’s motion for summary judgment, as Micki’s statements were opinions and thus were nonactionable. View "Scholz v. Delp" on Justia Law

After a jury trial, Defendant was found guilty of murder in the first degree. The Supreme Judicial Court affirmed the convictions and the trial court’s denial of Defendant’s motion for a new trial and declined to reduce the degree of guilt pursuant to Mass. Gen. Laws ch. 278, 33E, holding (1) there was sufficient evidence to sustain Defendant’s conviction; (2) Defendant suffered no prejudice as a result of the Commonwealth’s failure to disclose certain evidence; (3) there was no error due to the Commonwealth’s exclusion of third-party culprit evidence; (4) the judge judge did not abuse her discretion in denying Defendant’s motion to exclude hearsay statements by the victim’s girl friend; (5) the prosecutor did not engage in impermissible misconduct; (6) defense counsel’s performance was not constitutionally deficient; and (7) Defendant failed to establish that a new trial was required because the prosecutor had represented him on several previous occasions. View "Commonwealth v. Watkins" on Justia Law

In 1995, Randall Trapp and four other inmates, who were adherents of Native American religious practices, filed a complaint asserting that the Department of Correction (DOC) had violated their rights to exercise their religion. In 2003, the parties entered into a settlement agreement requiring the DOC to construct a purification lodge at the Souza-Baranowski Correctional Center (SBCC). Within six months of building the SBCC lodge, the DOC halted all ceremonies, citing health concerns that resulted from smoke filtering into the main building from wood fires at the lodge. In 2010, Trapp and Robert Ferreira filed an amended complaint against the Commissioner of Correction and two DOC employees at the Massachusetts Correctional Institution at Norfolk, alleging that the lodge’s closure violated the Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA), article 2 of the Massachusetts Declaration of Rights, and the 2003 settlement agreement. A superior court judge entered a declaratory judgment in favor of Plaintiffs on all three claims. The Supreme Judicial Court affirmed, holding that the closure of the SBCC lodge violated RLUIPA and the settlement agreement. View "Trapp v. Roden" on Justia Law

After a jury trial, Defendant was found guilty of murder in the first degree on the theory of deliberate premeditation. The Supreme Judicial Court affirmed Defendant’s conviction and declined to grant relief pursuant to Mass. Gen. Laws ch. 278, 33E, holding that the trial judge did not err by (1) permitting the Commonwealth’s DNA expert to testify about the results of DNA testing performed by another analyst, who was not available to testify; (2) limiting direct examination of Defendant’s primary mental health expert witness; (3) instructing the jury regarding the consequences of a verdict of not guilty by reason of lack of criminal responsibility; and (4) not limiting the jury’s consideration of evidence of consciousness of guilt solely to the issue of Defendant’s mental state at the time of the crime. View "Commonwealth v. Chappell" on Justia Law

In 1983, Petitioner was convicted of murder in the first degree. In 2013, Petitioner filed in the trial court a motion for appointment of counsel to filed for forensic and scientific analysis pursuant to Mass. Gen. Laws 278A, 5. The judge denied Petitioner’s motion. Petitioner then filed in the county court a petition seeking relief pursuant to Mass. Gen. Laws ch. 211, 3 and Mass. Gen. Laws ch. 278, 33E to pursue issues related to chapter 278A. A single justice denied the petition, and Petitioner appealed. The Supreme Judicial Court affirmed, holding (1) to the extent that Petitioner sought relief pursuant to chapter 211, section 3, his petition was properly denied on the basis that he had an adequate alternative remedy; but (2) Petitioner properly sought leave to appeal from the denial of his motion for appointment of counsel pursuant to the gatekeeper provision of chapter 278, 33E. Remanded. View "Monteiro v. Commonwealth" on Justia Law