Justia Massachusetts Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of murder in the first degree on a theory of deliberate premeditation. Defendant filed a motion for a new trial, asserting that his trial counsel provided ineffective assistance. The trial judge denied the motion. The Supreme Judicial Court vacated Defendant’s conviction and remanded for a new trial, holding that Defendant’s counsel did not prepare for trial in an adequate manner and that counsel’s deficient performance at trial, where Defendant’s defense was presented “poorly and incompletely,” created a substantial likelihood of a miscarriage of justice. View "Commonwealth v. Alcide" on Justia Law

After a jury trial, Defendant was convicted of two counts of trafficking in oxycodone. Defendant’s appeal from his convictions was pending at the time of this opinion. Here, Defendant appealed from two judgments of a single justice of the Supreme Judicial Court. The first judgment concerned a “petition for appeal to [the] Supreme Judicial Court pursuant to [Mass. Gen. Laws ch. 278, 28]”, and the second judgment concerned a petition that Defendant subsequently filed in the count court pursuant to Mass. Gen. Laws ch. 211, 3. The single justice denied both petitions. The Supreme Judicial Court affirmed, holding (1) the single justice was correct to deny the petition pursuant to chapter 278 section 28 because the statute does not give a defendant the right to petition in the Court in lieu of, or in addition to, his direct appeal in the appeals court; and (2) Defendant’s petition pursuant to chapter 211 section 3 was also without merit. View "DeMatos v. Commonwealth" on Justia Law

Defendant was convicted of two counts of murder in the first degree. Defendant was sixteen years old at the time of the crimes. Defendant was sentenced in 1994 to two consecutive sentences of life without the possibility of parole. At the time of his sentencing, the distinction between consecutive and concurrent sentences had little practical impact, but the Supreme Judicial Court’s subsequent decisions in Diatchenko v. District Attorney for the Suffolk Dist. and Commonwealth v. Brown changed that. In the wake of the Court’s decisions in Diatchenko and Brown, Defendant moved for resentencing. The trial court judge concluded that Defendant was entitled to a resentencing proceeding on the issue of whether the sentences should be imposed consecutively or concurrently. The Supreme Judicial Court affirmed, holding that a trial court judge, in resentencing a juvenile offender originally sentenced to multiple consecutive terms of life without the possibility of parole, may conduct a sentencing hearing to consider resentencing the juvenile offender to concurrent terms. Remanded. View "Commonwealth v. Costa" on Justia Law

After a jury trial, Defendant was convicted of rape, unarmed robbery, and kidnapping. The appeals court affirmed. Defendant was subsequently paroled, but his parole was revoked when he pleaded guilty to larceny over $250. In 2013, Defendant filed a postconviction motion under Mass. Gen. Laws ch. 278A, 3 for forensic or scientific analysis of certain evidence presented at his trial and for discovery regarding the location of other items referenced at trial but not admitted into evidence. Specifically, Defendant sought DNA testing of the evidence presented at trial and potential DNA testing of the remaining items at issue. A judge denied Defendant’s motion. The Supreme Judicial Court reversed the judge’s order denying Defendant’s section 3 motion except insofar as it denied Defendant’s request for discovery, holding (1) Defendant met the requirements of Mass. Gen. Laws ch. 278A, 3; (2) the judge erred in determining that Defendant was required to establish the existence of biological material on the evidence admitted into evidence; (3) the judge properly denied Defendant’s request for discovery; and (4) the judge must make findings of fact and conclusions of law regarding whether Defendant satisfied Mass. Gen. Laws. ch. 278A, 7(b)(2), (3), (5), and (6). Remanded. View "Commonwealth v. Clark" on Justia Law

After a jury trial, Defendant was convicted of deliberately premeditated murder. On appeal, Defendant filed a motion for a new trial and a motion for funds for an investigator. The trial judge denied the motions without a hearing and also denied Defendant’s motion for reconsideration. The Supreme Judicial Court affirmed the convictions and the denial of Defendant’s postconviction motions, holding (1) the judge did not abuse his discretion in concluding that Defendant failed to meet his burden of proof when he denied Defendant’s claim of ineffective assistance of counsel as contained in his motions for a new trial and for reconsideration; and (2) the judge’s conclusion that Defendant’s claim of newly discovered evidence could not be ascertained was neither erroneous nor an abuse of discretion. View "Commonwealth v. Gorham" on Justia Law

The Town of Mendon adopted a bylaw prohibiting the sale or presence of alcohol at adult entertainment establishments. Showtime Entertainment, LLC, which sought to operate an adult entertainment establishment within the Town and to serve alcohol on the premises, brought suit in federal court seeking to invalidate the bylaw. The United States Court of Appeals for the First Circuit certified questions to the Supreme Judicial Court focusing on parts of the test employed to determine the constitutionality of “content-neutral” restrictions on expressive behavior as first outlined in United States v. O’Brien. The Supreme Judicial Court answered (1) the Town in this case utilized evidence sufficient to demonstrate a countervailing State interest to justify the restriction at issue; but (2) the bylaw was not adequately tailored to pursue the Town’s goal of crime prevention. View "Showtime Ent., LLC v. Town of Mendon" on Justia Law

In 2002, Defendant was convicted of indecent assault and battery on a child under the age of fourteen, which qualifies as a “sexual offense” under Mass. Gen. Laws ch. 123A, 1. In 2013, Defendant was indicted for failure to register as a sex offender, subsequent offense. Defendant was unable to post bail on his pending indictment and remained in custody solely for that reason until trial. In 2014, the Commonwealth filed a petition pursuant to Mass. Gen. Laws ch. 123A, 12 to civilly commit Defendant as a sexually dangerous person (SDP). Defendant moved to dismiss the petition, claiming that the district attorney was not authorized to file a petition against him under the circumstances. The trial judge denied the motion, concluding that section 12 contemplates the SDP commitment of persons previously convicted of a sexual offense who are currently serving a criminal sentence or who face pending charges and are awaiting trial. The Supreme Judicial Court reversed, holding that the Commonwealth may not file an SDP petition under section 12 against a person such as Defendant, who is in custody only because he is awaiting trial, unless a judge has found the defendant incompetent to stand trial. View "Commonwealth v. Libby" on Justia Law

George and Sandra Schussel filed no tax returns between 1989 and 2007. In 2007, George was convicted of federal conspiracy and tax evasion charges. Thereafter, the Commissioner of Revenue issued the Schussels a notice of failure to file Massachusetts income tax returns for the years 1993 to 1995. The Schussels filed tax returns for those years, but the Commissioner determined that the returns were “false or fraudulent” or to have been filed with an intent to evade taxes. Consequently, the Commissioner imposed a “double assessment” against the Schussels. The Commission denied the Schussels request for abatement of the double assessment. The Appellate Tax Board and the Appeals Court affirmed the Commissioner’s decisions. The Supreme Judicial Court affirmed, holding (1) the Board’s findings of fact were supported by substantial evidence; and (2) the Schussels’ claim that they were entitled to relief from the double assessment under an amnesty program established by the Commissioner in 2009 was not properly before the Court. View "Schussel v. Comm’r of Revenue" on Justia Law

Defendant was charged with one count of assault and battery on a family member. Prior to Defendant’s release upon arraignment, the Commonwealth submitted a preliminary written statement pursuant to Mass. Gen. Laws ch. 276, 56A, alleging that domestic abuse occurred immediately prior to or in conjunction with Defendant’s charged offense. The judge declined to rule that domestic abuse was alleged in connection with the charged offense and reported the case to the Appeals Court, opining that section 56A in part violated Defendant’s constitutional guarantee of due process and separation of powers by interfering with the judicial function. The case was entered in the Appeals Court, and the Supreme Judicial Court granted Defendant’s application for direct appellate review. The Supreme Judicial Court responded to the judge’s report by holding that section 56A requires that before a judge makes a “written ruling that abuse is alleged in connection with the charged offense,” the judge must inquire into and be satisfied that there is an adequate factual basis for the abuse allegations made by the Commonwealth. View "Commonwealth v. Dossantos" on Justia Law

A Massachusetts grand jury issued indictments against Defendants, Nickoyan Wallace and Timi Wallace, accusing them of murder. Defendants were in federal custody from 2000 until 2009. Not until 2009 did prosecutors initiate the necessary steps to gain custody of Defendants from federal prison authorities under the Interstate Agreement on Detainers. Defendants were subsequently arraigned in superior court. Defendants filed motions to dismiss, alleging that the Commonwealth’s delay in obtaining custody of them from federal prison authorities impermissibility affected their right to a speedy trial. A superior court judge found that Timi’s right to a speedy trial had not been violated but that of Nickoyan had. The Appeals Court affirmed in part and reversed in part, concluding that the Commonwealth had not violated the speedy trial right of either defendant. The Supreme Judicial Court affirmed the trial court’s decision to deny Timi’s motion and to allow Nickoyan’s motion, holding that, under the circumstances of this case, Nickoyan’s right to a speedy trial was violated under the circumstances of this case but that Timi’s was not. View "Commonwealth v. Wallace" on Justia Law