Justia Massachusetts Supreme Court Opinion Summaries

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

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