Justia Massachusetts Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of murder in the second degree and of possession of a firearm without a license. Defendant appealed, arguing that his attorney’s concession in opening statement and closing argument that Defendant committed the killing was tantamount to a guilty plea and that because a colloquy did not take place between the judge and Defendant as to whether Defendant made the concession knowingly and voluntarily, he was entitled to a new trial. The Supreme Judicial Court affirmed the convictions, holding (1) no colloquy was required regarding defense counsel’s concession of guilt to the lesser included offense of manslaughter; and (2) because Defendant did not claim on appeal that he received ineffective assistance of counsel, there was no basis on which to vacate Defendant’s convictions. View "Commonwealth v. Evelyn" on Justia Law

Police officers stopped Defendant for driving with an unilluminated headlight. During the stop, the officers saw in the vehicle a one-ounce bag of marijuana. The officers ordered Defendant out of the vehicle and conducted a search of the vehicle in which they discovered two other bags of marijuana. Defendant was booked on charges of possession of marijuana with intent to distribute. The officers seized and searched Defendant’s cellular telephone, finding text messages they identified as being consistent with sales of marijuana. Defendant moved to suppress the marijuana found in his vehicle and the text messages discovered on his phone on the grounds that “police observation of one ounce or less of marijuana is insufficient, by itself, to give rise to the probable cause necessary to conduct a search.” The district court denied the motion to suppress, concluding that the officers were permitted to enter the vehicle to effect the forfeiture of the marijuana they saw. The Supreme Court reversed, holding that the officers’ entry into the vehicle was impermissible because they lacked probable cause to believe the vehicle contained evidence of a crime, and therefore, the evidence obtained as a result of the searches of Defendant’s vehicle and of his cellular telephone must be suppressed. View "Commonwealth v. Sheridan" on Justia Law

Defendant was indicted on a charge of receiving a stolen motor vehicle. Defendant moved to suppress evidence seized as a result of a warrantless search of his garage. A superior court judge denied the motion. After a joint trial of Defendant and his codefendant, Defendant was convicted. The Supreme Judicial Court affirmed, holding (1) the superior court judge did not err in denying Defendant’s motion to suppress, as the warrantless entry into the garage was justified by exigent circumstances; (2) the trial court did not err in admitting recordings of jailhouse telephone calls between Defendant and his codefendant; and (3) the evidence was sufficient to support Defendant’s conviction. View "Commonwealth v. Ramos" on Justia Law

After a jury trial in 1984, Defendant was convicted of aggravated rape. In 2006, Defendant filed a series of motions to test the victim’s clothing for DNA. The motions were granted. The State police crime laboratory and an independent laboratory performed DNA testing on the evidence. Thereafter, Defendant filed a motion for a new trial, relying on the affidavit of a forensic analyst employed by the Connecticut State laboratory, who stated his opinion that Defendant was excluded as the source of the male DNA on the victim’s clothing. After an evidentiary hearing, the motion judge denied the motion for a new trial, determining that the forensic analysts’s opinion was not sufficiently reliable to be placed before a jury. The Appeals Court affirmed. The Supreme Judicial Court affirmed the denial of Defendant’s motion for a new trial, holding (1) Defendant failed to establish that the forensic analyst’s opinion was reliable, and therefore, the opinion was properly excluded from reaching the trier of fact; and (2) the newly available, admissible evidence regarding the DNA testing would not be capable of casting meaningful doubt on the jury’s verdict that Defendant was the perpetrator of the rape. View "Commonwealth v. DiCicco" on Justia Law

Following a jury-waived trial, Defendant was convicted of possession of a class B substance. The Appeals Court reversed and directed the entry of judgment for Defendant, concluding that the evidence on the record was insufficient to establish constructive possession. The Supreme Judicial Court allowed the Commonwealth’s application for further appellate review limited to the issues concerning the sufficiency of the evidence. The Court affirmed the district court, holding that the trial judge, as finder of fact, was amply warranted in finding that Defendant intended to exercise dominion and control over a bag of PCP found in a vehicle in which he was a passenger. View "Commonwealth v. Cullity" on Justia Law

After a jury trial, Defendant was convicted of intimidating a witness, carrying a firearm without a license, discharging a firearm within 500 feet of a building, and assault by means of a dangerous weapon. The Supreme Judicial Court vacated the convictions and remanded for a new trial, holding that the trial judge (1) did not abuse his discretion in admitting two photographs of a handgun that looked like the unrecovered handgun fired by Defendant; (2) did not err in denying Defendant’s motion for a required finding of not guilty; but (3) erred in allowing the Commonwealth to present a witness’s prior recorded testimony without sufficient proof of the witness’s unavailability, and the error was not harmless beyond a reasonable doubt. View "Commonwealth v. Housewright" on Justia Law

During a house party in 2008, multiple guests, who were Caucasion, committed acts of physical violence against an African-American. Amanda Kelly was convicted of a violation of civil rights with bodily injury. Christopher Bratlie and Kevin Shdeed were both convicted of a violation of civil rights without bodily injury. All defendants were convicted of assault and battery for the purpose of intimidation. Bratlie was further convicted of assault and battery as a lesser included offense of assault and battery by means of a dangerous weapon and assault and battery. The Supreme Judicial Court (1) affirmed Kelly’s and Shdeed’s convictions, holding that the trial judge did not err in not instructing the jury that in order to convict Defendants of assault and battery for the purpose of intimidation, the jury must find that race was a substantial factor motivating the defendants’ unlawful conduct; and (2) vacated Bratlie’s conviction of a second count of assault and battery as duplicative, and affirmed his remaining convictions. View "Commonwealth v. Kelly" on Justia Law

In 2008, Defendant pleaded guilty to distribution of a class B substance and was sentenced to serve one year in a house of correction. In 2013, because of the problems that arose at the William A. Hinton State Laboratory and Annie Dookhan in particular, Defendant filed a motion to withdraw his guilty plea and for a new trial. The district court denied the motion. The Supreme Judicial Court subsequently decided Commonwealth v. Scott, in which the Court considered the effect of Dookhan’s misconduct on a defendant’s motion to withdraw a guilty plea on the basis of that misconduct. The Supreme Judicial Court vacated the order denying Defendant’s motion and remanded for further consideration in accordance with Scott and this decision, holding that Defendant was entitled to an opportunity to demonstrate egregious government misconduct in his case. View "Commonwealth v. Torres" on Justia Law

After the parties in this case separated, a California court entered a judgment establishing monthly child and spousal support payments payable by Father to Mother. Father subsequently moved to Massachusetts, and the California support order was registered in the probate and family court. Thereafter, the child support division of the Massachusetts Department of Revenue initiated contempt proceedings against Father. A probate and family court judge issued multiple orders that sought to enforce the California support order. The orders incorporated the parties’ stipulated agreements regarding issues that had not been included in the order of the California court. Several years later, the probate and family court found Father in contempt for having failed to make certain payments. The Supreme Judicial Court affirmed in part and reversed in part, holding (1) to the extent the probate and family court orders modified the California support order, they were void, as the stipulated agreements did not extend the jurisdiction of the probate and family court to modify the California support order; and (2) the probate and family court had authority to hold Father in contempt for failing to comply with the probate and family court’s orders that sought to enforce the California support order. View "Cohen v. Cohen" on Justia Law

Plaintiffs in this case were two companies subject to the five percent excise tax on video programming delivered by direct broadcast satellite. Plaintiffs brought a complaint for declaratory and injunctive relief alleging that the tax violates the Commerce Clause of the federal Constitution because it disfavors satellite companies as compared with those companies that provide video programming via cable. A superior court judge granted summary judgment in favor of Defendant, the Department of Revenue. The Supreme Judicial Court affirmed, holding that the cable and satellite companies are not similarly situated, and therefore, Plaintiffs failed to carry their burden of establishing that the excise tax statute was motivated by a discriminatory purpose. View "DIRECTV, LLC v. Dep’t of Revenue" on Justia Law