Justia Massachusetts Supreme Court Opinion Summaries

Defendant pleaded guilty to trafficking in cocaine and unlawful possession of ammunition. Two years later, Sonja Farak, a chemist at the Department of Public Health’s State Laboratory Institute in Amherst during the time of Defendant’s criminal case, was indicted on numerous counts of tampering with evidence, theft of a controlled substance from a dispensary, and unlawful possession of a class B substance. Three weeks later, Defendant filed a motion to withdraw his guilty pleas pursuant to Mass. R. Crim. P. 30(b), alleging that Farak’s misconduct cast serious doubt on the justice of his convictions. A superior court judge denied Defendant’s motion. Farak subsequently pleaded guilty to all charges. The Supreme Judicial Court vacated the order denying Defendant’s motion to withdraw his guilty pleas, holding that, due to the Commonwealth’s failure to thoroughly investigate Farak’s misconduct at the Amherst drug lab, Defendant was entitled to a measure of relief. Remanded. View "Commonwealth v. Cotto" on Justia Law

Between 2004 and 2013, Defendant was indicted on drug charges in three separate cases. Also during that time, Sonja Farak was a chemist at the Department of Public Health’s State Laboratory Institute in Amherst. Farak later pleaded guilty to several counts of tampering with evidence, theft of a controlled substance from a dispensary, and unlawful possession of cocaine. Based on Farak's misconduct, Defendant filed a motion pursuant to Mass. R. Crim. P. 30(c)(4) for leave to conduct postconviction discovery and for funds with respect to the three cases that had been brought against him. Defendant sought retesting of drug evidence maintained by the Springfield police department that related to the cases brought by the Commonwealth between 2004 and 2013. The superior court judge denied Defendant’s motion for leave to conduct postconviction discovery, concluding that Defendant failed to establish a prima facie case for relief under Rule 30(c)(4). The Supreme Judicial Court affirmed the order but remanded for further proceedings, holding that Defendant was entitled to retest the controlled substance that gave rise to his 2009 indictment charging distribution of cocaine as a subsequent offense. View "Commonwealth v. Ware" on Justia Law

In 2012, the Governor nominated Michael McCarthy for a Massachusetts judgeship. The nomination failed to garner the necessary votes for confirmation. Nearly one month later, Mary-Ellen Manning, a former member of the Executive Council, who had initially abstained from voting, delivered a letter to the Governor stating that she consented to the appointment of McCarthy. Neither the Governor nor the Secretary took further steps regarding McCarthy’s nomination in response to the letter. In 2013,the Governor resubmitted McCarthy’s nomination to the Council for the same judicial position. The nomination again failed to garner the votes needed for confirmation. The Governor never signed, and the Secretary of the Commonwealth never issued, a commission to McCarthy. McCarthy and Manning later filed a complaint against the Governor and the Secretary seeking to establish that McCarthy’s first nomination had resulted in his successful appointment to the judgeship, and therefore, McCarthy was entitled to a commission for that office. A single justice of the Supreme Judicial Court declined to grant the requested relief. The Supreme Judicial Court affirmed, holding that because the Governor took no action to effectuate a judicial appointment and the Secretary had no legal duty to act, Plaintiffs were not entitled to relief. View "McCarthy v. The Governor" on Justia Law

Defendant was on trial on indictments charging murder in the first degree and various firearm offenses. Before trial, the Commonwealth filed a motion in limine seeking to establish the admissibility of testimony from a certain witness as to conversations the witness had with Defendant. After the trial began, the trial judge denied the motion. The Commonwealth sought relief from a single justice of the Supreme Judicial Court pursuant to Mass. Gen. Laws ch. 211, 3. The single justice denied the petition. The Supreme Judicial Court affirmed, holding that the Commonwealth failed to demonstrate that the single justice committed a clear error of law or abused his discretion when he denied the Commonwealth’s petition. View "Commonwealth v. Hernandez" on Justia Law

Defendant was a participant in a drive-by shooting against a group of young men that killed one member of the group and wounded two others. The Supreme Judicial Court affirmed the convictions and declined Defendant’s request that it grant relief under Mass. Gen. Laws ch. 278, 33E, holding (1) the trial court did not err in admitting the grand jury of a Commonwealth witness; (2) the trial court did not err in admitting prior bad act evidence; (3) the trial court did not err in admitting evidence of Defendant’s refusal to have his custodial interrogation recorded; (4) the trial court did not err in admitting evidence of 911 calls received by a police dispatcher; (5) the trial court erred in admitting evidence concerning the course of the investigation and the role of the grand jury, but the error did not prejudice Defendant; (6) the prosecutor’s impeachment of a defense witness with her failure to report exculpatory evidence to police was not in error; (7) the prosecutor did not engage in impermissible misconduct during closing argument; and (8) the trial judge did not err in declining to give a Bowden instruction. View "Commonwealth v. DaSilva" on Justia Law

Defendant was convicted of murder in the second degree and received a mandatory sentence of life imprisonment with eligibility for parole after fifteen years. Defendant was fifteen years old at the time of the offense. Defendant appealed, arguing, among other things, that his mandatory life sentence constituted cruel and unusual punishment in violation of the Eighth Amendment to the U.S. Constitution and article 26 of the Massachusetts Declaration of Rights. The Supreme Judicial Court affirmed, holding (1) a mandatory life sentence with eligibility for parole after fifteen years for a juvenile homicide offender convicted of murder in the second degree does not offend the Eighth Amendment or article 26 or other constitutional rights; and (2) Defendant’s challenges to his underlying conviction were without merit. View "Commonwealth v. Okoro" on Justia Law

In 2013, Gregory Diatchenko filed the present action seeking a declaration that, because he was seventeen at the time he committed the offense leading to his conviction of murder in the first degree, his mandatory sentence of life without parole was unconstitutional. Following Miller v. Alabama, the Supreme Judicial Court determined that the mandatory imposition of such a sentence was unconstitutional. The Court held that a juvenile homicide offender who receives a mandatory sentence of life imprisonment must be afforded the opportunity for release on parole. Diatchenko and another petitioner, both of whom became immediately eligible for parole pursuant to the Court’s decision in Diatchenko I, contended that, to ensure their opportunity for release through parole was meaningful, they must have access to counsel, access to funds for counsel and for expert witnesses, and an opportunity for judicial review of the decision on their parole applications. The Supreme Judicial Court agreed with the petitioners, holding (1) the procedural protections of representation by counsel and the opportunity to obtain expert assistance in connection with that initial parole hearing are necessary for juvenile homicide offenders serving a mandatory life sentence; and (2) such offenders are entitled to limited judicial review of a parole board decision denying initial parole. View "Diatchenko v. District Attorney" on Justia Law

Defendants were convicted of possession of heroin and possession of firearms and ammunition. Defendants appealed, arguing, inter alia, that there was insufficient evidence to support their convictions. The Supreme Judicial Court affirmed in part and reversed in part, holding (1) the Commonwealth presented sufficient evidence to support Defendants’ convictions of possession of heroin; but (2) the Commonwealth did not present sufficient evidence to support a conclusion beyond a reasonable doubt that Defendants constructively possessed the firearms and ammunition found in the apartment in which they were staying. View "Commonwealth v. Dagraca-Teixeira" on Justia Law

Steven Fitzgerald pleaded guilty to certain criminal offenses. Fitzgerald subsequently filed a petition for relief under Mass. Gen. Laws ch. 211, 3 seeking to vacate his pleas, arguing that he was forcibly medicated when he tendered his pleas and that he has not been able to obtain a copy of a court file of an earlier proceeding which resulted in an order that he be involuntarily committed and treated with antipsychotic medications before he pleaded guilty. A single justice of the Supreme Judicial Court denied extraordinary relief. The Supreme Judicial Court affirmed, holding that Fitzgerald was not entitled to extraordinary relief under the circumstances of this case. View "Fitzgerald v. Dist. Court Dep’t of the Trial Court" on Justia Law

In 2011, Defendant was indicted on a charge of violating Mass. Gen. Laws ch. 94C, 32E(b)(2) for trafficking in cocaine with a total weight of 28.14 grams. In 2012, St. 2012, ch. 192 (Crime Bill) was enacted, which amended section 32E(b)(2), along with section 32E(b)(1), to redefine the minimum and maximum trafficking weights. The Crime Bill also reduced the mandatory minimum sentence required for a violation of both section 32(e)(b)(1) and (2). Prior to trial, Defendant filed a motion to apply all the Crime Bill’s amendments to section 32E(b)(1) and (2) to his case. The judge allowed Defendant’s motion. The Supreme Judicial Court affirmed in part and reversed in part, holding that, in accordance with Commonwealth v. Galvin, (1) the Crime Bill’s reduction of the mandatory minimum sentence required for a violation of section 32(b)(2) applies retroactively to Defendant; but (2) the reconfigured drug trafficking weights provided in sections 32E(b)(1) and (2), as amended by the the Crime Bill, do not apply retroactively to Defendant. Remanded. View "Commonwealth v. Didas" on Justia Law