Justia Massachusetts Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of murder in the second degree, unlawful possession of a firearm, unlawful possession of a loaded firearm, and unlawful possession of ammunition. The Supreme Judicial Court affirmed Defendant’s convictions, holding (1) the trial judge’s refusal to grant immunity to two potential defense witnesses did not violate Defendant’s right to a fair trial and due process of law, nor his right to present a complete defense; and (2) the prosecutor did not engage in improper vouching or misstate the evidence in during closing arguments. View "Commonwealth v. Brewer" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on the theory of felony-murder. Defendant appealed, arguing, inter alia, that the trial court erred in its partial denial of his motion to suppress statements he made after being taken involuntarily into the police station. The Supreme Judicial Court affirmed, holding (1) Defendant’s motion to suppress should have been allowed in its entirety because these statements were the inadmissible fruits of an unlawful arrest, but the error did not create a substantial likelihood of a miscarriage of justice; (2) the trial court did not err in denying defense counsel’s motion to withdraw from the case two days before trial; and (3) Defendant’s claim that his counsel provided ineffective assistance lacked merit. View "Commonwealth v. Melo" on Justia Law

After a jury trial, Defendant was convicted of seven indictments charging offenses under Mass. Gen. Laws ch. 265, 13J(b), which imposes criminal penalties on a person who wantonly or recklessly permits bodily injury to a child in his care or wantonly or recklessly permits another to commit an assault and battery causing bodily injury upon such a child. The seven indictments were each based on a distinct injury or set of injuries to the victim. Defendant appealed, contending that the indictments were duplicative. The Supreme Judicial Court reversed all but one of Defendant’s convictions, holding that, to establish multiple violations of Mass. Gen. Laws ch. 265, 13J(b), the Commonwealth may not establish multiple convictions solely by showing multiple injuries to a single child but, rather, must prove either that the defendant engaged in separate and discrete instances of criminal conduct or that multiple victims were harmed as a result of the defendant’s criminal conduct. View "Commonwealth v. Traylor" on Justia Law

Plaintiff, acting on behalf of his minor son, commenced this negligence action against the City of Somerville. The City filed a motion to dismiss under Mass. R. Civ. P. 12(b)(6), claiming that Plaintiff failed to meet the statutorily-required presentment requirements. The superior court denied the motion. The City appealed, arguing that its interlocutory appeal was proper under the doctrine of present execution. The Appeals Court dismissed the City’s appeal, concluding that the doctrine of present execution did not apply. The Supreme Judicial Court reversed, holding (1) the City’s appeal was not moot; (2) the appeal was proper under the doctrine of present execution; and (3) the City’s motion to dismiss Plaintiff’s complaint should have been allowed because presentment in this case was deficient. View "Rodriguez v. City of Somerville" on Justia Law

After a jury trial, Defendant was convicted of deliberately premeditated murder. Defendant appealed, claiming evidentiary error and prosecutorial misconduct. The Supreme Judicial Court affirmed the conviction and declined Defendant’s request for relief under Mass. Gen. Laws ch. 278, 33E, holding (1) the district judge did not abuse his discretion in admitting evidence of an autopsy photograph; (2) the district judge did not abuse his discretion in admitting a BB rifle together with ammunition that were unrelated to the killing; and (3) the prosecutor did commit impermissible misconduct during closing arguments. View "Commonwealth v. Carney" on Justia Law

After a jury trial, Defendant was convicted of larceny of a motor vehicle. The Commonwealth nol prossed the portion of the indictment that alleged a second or subsequent offense. Defendant filed motions pursuant to Mass. R. Crim. P. 30 and, before the motions were acted on, filed a Mass. Gen. Laws ch. 211, 3 petition, arguing that the Commonwealth could not nol pros only a portion of the indictment. A single justice of the Supreme Judicial Court denied Defendant’s petition for extraordinary relief. The Supreme Judicial Court affirmed, holding that Defendant had an adequate alternative remedy by way of appeal. View "Carrington v. Commonwealth" on Justia Law

Plaintiffs granted a mortgage on their property to Emigrant Mortgage Company, Inc. Emigrant later foreclosed on the mortgage by exercise of the power of sale contained in the mortgage. Harold Wilion purchased the property at the foreclosure sale. Plaintiffs brought this action against Emigrant and Wilion, seeking a judgment declaring that the sale was void because Emigrant failed to comply with paragraph 22 of the mortgage, which contains the mortgagee’s provision of notice to the mortgagor of default and the right to cure, as well as the remedies available to the mortgagee upon the mortgagor’s failure to cure the default. The superior court allowed Emigrant’s motion to dismiss and Wilion’s motion for summary judgment, concluding that Emigrant was not required strictly to comply with the notice of default and right-to-cure provisions of paragraph 22 of the mortgage. The Supreme Judicial Court reversed, holding (1) strict compliance with the notice of default provisions in paragraph 22 was required as a condition of a valid foreclosure sale; and (2) Emigrant failed to meet the strict compliance requirement. Remanded. View "Pinti v. Emigrant Mortgage Co., Inc." on Justia Law

In the underlying case, certain parties moved for sanctions against Attorney on the grounds that he had violated the rules of professional conduct and interfered with the effective administration of justice. The judge ordered Attorney to reimburse all parties their attorney’s fees as a sanction for his misconduct. The judge assessed attorney’s fees against Attorney without the authority of any statute or rule, in the absence of any violation of a court order or rule of procedure, and in the absence of any contractual arrangement among the parties authorizing the assessment of attorney’s fees. The Supreme Judicial Court reversed the judge’s order imposing sanctions, holding (1) a judge may exercise the court’s inherent power to sanction an attorney by imposing attorney’s fees only if the attorney has engaged in misconduct that threatens the fair administration of justice and the sanction is necessary to preserve the judge’s authority to administer justice; and (2) under the circumstances of this case, the judge abused his discretion in exercising the court’s inherent powers to sanction Attorney. View "Wong v. Luu" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree and aggravated rape. The Supreme Judicial Court affirmed in part and reversed in part, holding (1) the evidence was insufficient to support Defendant’s conviction of aggravated rape; (2) the trial court did not err in admitting opinion testimony of a criminalist with the State police crime laboratory; (3) the trial court erred in admitting an autopsy report prepared by a medical examiner who did not testify at trial and in admitting the testimony of a substitute medical examiner, but the admission of this evidence did not create a substantial likelihood of miscarriage of justice; (4) the trial court did not err in admitting a witness’s testimony that she recognized Defendant as a patron of a bar in which the victim was seen on the night of her death; (5) the prosecutor committed error during closing arguments, but Defendant was not prejudiced by the errors; and (6) the trial judge did not err in declining to instruct the jury in accordance with Defendant’s proposed instruction on third-party culprit evidence. View "Commonwealth v. Scesny" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on the theory of extreme atrocity or cruelty. The Supreme Judicial Court affirmed the convictions, holding that the trial judge did not err in (1) admitting into evidence a cellular telephone text message sent by the victim; (2) granting the Commonwealth leave to present general evidence that Defendant made statements - which were previously suppressed - to impeach proffered evidence that he was noncommunicative; (3) excluding the testimony of a defense expert witness; and (4) instructing the jury on diminished capacity. View "Commonwealth v. Mulgrave" on Justia Law