Justia Massachusetts Supreme Court Opinion Summaries

After a jury trial, Defendant was found guilty of rape of a child by force and of assault with intent to rape a second child. The Appeals Court affirmed. Defendant appealed, arguing that the admission of evidence relating to a prior acquittal deprived him of his right to a fair trial and due process. The Supreme Judicial Court reversed Defendant’s convictions, holding (1) there was no error in the admission of the evidence on relevancy grounds; but (2) the collateral estoppel protections necessarily embraced by article 12 of the Massachusetts Declaration of Rights warranted the exclusion of the acquittal evidence under the circumstances of this case. View "Commonwealth v. Dorazio" on Justia Law

At issue in this appeal was an ordinance imposing restrictions on the right of sex offenders to reside in the City of Lynn. Plaintiffs, a class of sex offenders subject to the ordinance, challenged the ordinance's constitutionality. A superior court judge invalidated the ordinance under the Home Rule Amendment. Specifically, the judge determined that the ordinance was inconsistent with the Sex Offender Registry Law and the law providing for the care, treatment, and rehabilitation of sexually dangerous persons. The Supreme Judicial Court affirmed, holding that the ordinance was inconsistent with the comprehensive statutory scheme governing the oversight of convicted sex offenders and, therefore, was inconsistent and invalid under the home rule provisions. View "Doe v. City of Lynn" on Justia Law

In 2008, Defendant was indicted on a charge of first-degree murder but was found not competent to stand trial until 2013. Thereafter, the Commonwealth filed a nolle prosequi with respect to the portion of the indictment that charged first-degree murder. Defendant filed a motion for a required finding of not guilty, which was denied. Defendant was subsequently found not guilty by reason of mental illness and ordered hospitalized. Defendant filed an appeal under Mass. Gen. Laws ch. 278, 28. The Commonwealth argued that Defendant may seek to pursue an appeal only by filing a petition for extraordinary relief under Mass. Gen. Laws ch. 211, 3 and that Defendant’s appeal does not lie under Mass. Gen. Laws ch. 278, 28 because a finding of not guilty by reason of mental illness is not a “judgment” and Defendant is not “aggrieved” since he has not been convicted. The Supreme Judicial Court affirmed, holding (1) a defendant who is found not guilty by reason of mental illness may appeal under Mass. Gen. Laws ch. 278, 28; and (2) the evidence in this case was sufficient to support a conviction of murder in the second degree, and therefore, the judge did not err in denying Defendant’s motion for a required finding of not guilty. View "Commonwealth v. Bruneau" on Justia Law

Defendants were indicted on charges of unarmed robbery and assault and battery. Defendants both committed the offenses prior to their eighteenth birthdays. The Governor subsequently signed an “Act expanding juvenile jurisdiction” that extended the jurisdiction of the juvenile court to children who are seventeen years of age at the time of committing an offense. Defendants filed motions to dismiss, arguing that the Act should be applied retroactively to seventeen-year-old defendants who had criminal charges pending against them as of the Act’s effective date and that a failure to apply the Act retroactively as to such defendants would violate their equal protection rights. The Supreme Judicial Court held (1) the Act does not apply retroactively to a defendant who commits an offense prior to his eighteenth birthday for which a criminal proceeding commenced prior to the effective date of the Act; and (2) prospective application of the Act does not violate the equal protection guarantees provided by the Fourteenth Amendment to the federal Constitution and article 1 of the Massachusetts Declaration of Rights, as amended by article 106 of the Amendments. View "Commonwealth v. Freeman" on Justia Law

John Doe was adjudicated a delinquent juvenile by reason of sex offenses and was committed to the Department of Youth Services. Defendant was later found to be a sexually dangerous person and was civilly committed for a period of from one day to life. Twenty years after Doe committed the offenses the Sex Offender Registry Board (SORB) classified him as a level three sex offender. Doe was later discharged from the treatment center based on the determination that he was no longer sexually dangerous. Doe brought this action contending, as relevant to this appeal, that the hearing examiner’s determination that he is a level three sex offender was unsupported by substantial evidence, in part because the evidence underlying the classification was stale where the hearing resulting in the final classification took place more than three years before Defendant’s discharge. The Supreme Judicial Court agreed with Doe and remanded the matter, holding that because Doe’s final classification was was not based on current evidence of the relevant risk factors, Doe was entitled to a new evidentiary hearing at which SORB will bear the burden of establishing Doe’s current risk of reoffense and dangerousness to the community. View "Doe, Sex Offender Registry Bd. No. 3839 v. Sex Offender Registry Bd." on Justia Law

John Doe, Sex Offender Registry Board No. 7083, was serving a criminal sentence and had been civilly committed as a sexually dangerous person when the Sex Offender Registry Board (SORB) notified him of its recommendation that he be classified as a level three sex offender. When a classification hearing took place in February 2012 Doe’s earliest parole eligibility date was ten months away and a trial on Doe’s petition for discharged was eighteen months away. Doe requested that the classification hearing be continued or left open. The hearing examiner denied the requests and classified Doe as a level three sex offender. The superior court and appeals court affirmed. Doe appealed, arguing that, by scheduling the classification hearing based on his earliest possible parole eligibility date, the information relied on by the hearing examiner in reaching a classification decision will have become stale by the time Doe is released from confinement. The Supreme Judicial Court vacated SORB’s decision and the superior court’s order affirming that determination, holding that, because the 2012 classification of Doe as a level three sex offender will not reflect an evaluation of his current level of risk at the time of his discharge from the treatment center, the decision classifying Doe as a level three offender is invalid. View "Doe, Sex Offender Registry Bd. No. 7083 v. Sex Offender Registry Bd." on Justia Law

After a jury trial, Defendant was convicted of several crimes based on three incidents that occurred in October 2010 when Defendant accosted three different teenage victims as they walked to school. On appeal, Defendant argued, among other things, that the motion judge erred in denying his motion to suppress statements that he made to police during a videotaped interview. The Supreme Judicial Court reversed, holding that the statements at issue were erroneously admitted at trial because the police engaged in impermissibly coercive tactics that rendered Defendant’s statements involuntary under the circumstances of the interrogation, and the error was not harmless beyond a reasonable doubt. Remanded for a new trial. View "Commonwealth v. Monroe" on Justia Law

Defendant was indicted for murder. Defendant filed a motion to suppress evidence of his cell site location information (CSLI) relating to his cellular telephone. The Commonwealth had obtained Defendant’s CSLI for a fourteen-day period beginning August 24, 2004 pursuant to the Federal Stored Communications Act under an order of the superior court judge. The superior court allowed the motion to suppress, concluding that obtaining Defendant’s CLSI constituted a search. In Augustine I, the Supreme Judicial Court agreed, holding that search a search would be permissible only upon a showing of probable cause. The Court vacated the allowance of the motion to suppress and remanded for consideration of whether the affidavit that the Commonwealth had submitted in support of the order demonstrated probable cause. On remand, the superior court again allowed Defendant’s motion to suppress evidence, ruling that the affidavit did not meet the probable cause standard required under Augustine I. The Supreme Judicial Court reversed, holding that the Commonwealth demonstrated probable cause for obtaining Defendant’s CSLI records for the period from August 24 to August 26, 2004. View "Commonwealth v. Augustine" on Justia Law

Boston police officers stopped a vehicle for a traffic infraction. The officers ordered the two rear seat passengers to get out of the vehicle and pat frisked each for weapons. Defendant, the front seat passenger, got out of the vehicle and was ordered to return to his seat. When he did so, he moved the gear shift to the “drive” position. Defendant and the driver were then ordered from the vehicle, and Defendant was pat frisked. Finding no weapon, the officers conducted a protective sweep of the vehicle and discovered a loaded firearm under the front passenger seat. Defendant was charged with unlicensed possession of a firearm and related offenses. Defendant moved to suppress the evidence seized as a result of the search. A superior court judge allowed the motion. The Supreme Judicial Court reversed the order allowing the motions to suppress, holding that, even if the pat frisks of the rear seat passengers were invalid, sufficient evidence supported the officers’ suspicion that Douglas might be armed and dangerous and that a limited protective sweep of the vehicle was necessary for officer safety. View "Commonwealth v. Douglas" on Justia Law

Defendant fled when two Boston police officers attempted to stop and question him. When the officers apprehended Defendant, a handgun containing ammunition fell from his pants. Defendant was charged with multiple firearms offenses and resisting arrest. Defendant moved to suppress the evidence obtained from the encounter. A municipal court judge allowed the motion to suppress. The Supreme Judicial Court affirmed, holding (1) the motion judge’s finding regarding the moment Defendant was seized was not erroneous; (2) the judge’s finding that the facts of this case did not support a conclusion of reasonable suspicion was not clearly erroneous; and (3) the Court was not permitted to make additional findings, and reach a different result, based on its own view of the evidence. View "Commonwealth v. Jones-Pannell" on Justia Law