Justia Massachusetts Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of murder in the second degree and other crimes. The trial judge denied Defendant’s motion for a new trial. The Supreme Judicial Court affirmed, holding (1) Defendant was not denied the effective assistance of counsel because of his attorney’s failure to object to the in-court identification of Defendant by an eyewitness and because of his attorney’s failure to object to the enforcement of a sequestration order during jury selection; (2) the trial judge did not err in denying Defendant’s motion for a new trial on the basis of prosecutorial misconduct; (3) the trial judge did not err in admitting cellular telephone records where the records were obtained by court order rather than with a search warrant; and (4) Defendant’s constitutional rights were not violated by his conviction of possession of an unlicensed firearm where Commonwealth didn’t prove that Defendant lacked a license to carry firearms. View "Commonwealth v. Collins" on Justia Law

In this case, the Supreme Judicial Court established a new standard for the admission of in-court identifications where the eyewitness had not previously participated in an out-of-court identification procedure. After a jury trial, Defendant was convicted on two indictments of possession of child pornography. The Supreme Judicial Court vacated the convictions, holding (1) under the new standard articulated today, the in-court identifications in this case could not have been admissible; (2) the trial judge erred in excluding from evidence Defendant’s denial to the police of having used library computers to view child pornography and in admitting into evidence three pornographic drawings of children found in Defendant’s possession; and (3) the admission of the in-court identifications and the trial errors resulted in unfair prejudice that required a new trial. View "Commonwealth v. Crayton" 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 Defendant’s convictions, holding (1) the trial court did not commit prejudicial evidentiary errors undermining Defendant’s right to present his defenses and depriving him of due process and fundamental fairness under the United States Constitution and Massachusetts Declaration of Rights; (2) an isolated misstatement by defense counsel during closing arguments did not create a substantial likelihood of a miscarriage of justice; and (3) the judge improperly responded to a question posed by the jury, but the response did not prejudice Defendant. View "Commonwealth v. Cassidy" on Justia Law

After a jury trial, Appellant was convicted of murder in the first degree. The Supreme Judicial Court affirmed the conviction. Appellant later filed a motion for a new trial, alleging that his trial counsel provided ineffective assistance by failing to impeach a witness as to one of his statements and that he was deprived of counsel when his trial counsel’s law partner stood in during jury deliberations. The motion was denied without a hearing. The Supreme Judicial Court affirmed, holding (1) trial counsel did not render ineffective assistance in failing to impeach a witness as to one of his statements or in allowing her partner to stand in for her during jury deliberations; and (2) any error in permitting substitute counsel to stand in for trial counsel was not structural warranting a new trial absent a showing of prejudice. View "Commonwealth v. Valentin" on Justia Law

At a hearing before a Juvenile Court judge, a juvenile admitted to sufficient facts with respect to two counts of indecent assault and battery on a person fourteen or older. The juvenile subsequently filed a motion seeking relief from the obligation to register as a sex offender. A judge denied the juvenile’s motion for relief from registration, determining that the juvenile posed a risk of reoffense and would be required to register with the Sex Offender Registry Board. The Supreme Court affirmed, holding that the judge’s ultimate determination that the juvenile should not be relieved of the obligation to register as a sex offender did not constitute an abuse of her discretion. View "L.L. v. Commonwealth" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on a theory of deliberate premeditation. On appeal, Defendant conceded that the evidence was sufficient to support the jury’s verdict and did not argue that any error occurred at trial. Rather, Defendant argued that the verdict was against the weight of the evidence where considerable evidence suggested that he acted in self-defense and also pointed to mitigation based on heat of passion. The Supreme Court affirmed, holding that Defendant’s trial was conducted fairly and without error, and there was no reason to reduce Defendant’s conviction to a lesser degree of guilt or to order a new trial. View "Commonwealth v. Ortiz" on Justia Law

Defendant, who was in the business of collecting and selling scrap metal, was convicted of larceny under $250 in connection with his removal of steel pipe from a construction site located on private property. Defendant claimed as an affirmative defense at trial that he lacked the requisite intent to steal because he honestly but mistakenly believed that the property he removed from the site was abandoned. The trial judge viewed the affirmative defense as requiring proof that Defendant’s belief was objectively reasonable. The Supreme Judicial Court vacated the conviction and remanded for a new trial, holding (1) an honest belief need not be objectively reasonable to negate the specific intent required for larceny; and (2) Defendant adequately raised the defense of honest belief that the items he took were abandoned, and it was the Commonwealth’s burden to prove beyond a reasonable doubt that Defendant’s subjective belief was not honestly held but, instead, was a pretense. View "Commonwealth v. Liebenow" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree. Defendant appealed, arguing that the trial court erred in denying his motion to suppress a surreptitiously recorded oral conversation between him and a police informant, that evidence of the conversation should have been excluded at trial, and therefore, that his conviction must be reversed. At issue before the Supreme Court was whether the one-party consent exception to the statutory prohibition against the secret recording or oral communications applied in this case. The Supreme Court reversed Defendant’s conviction, holding that the recorded conversation did not fit within the exception, that the conversation should not have been admitted in evidence at trial, and that the error was not harmless. View "Commonwealth v. Burgos" on Justia Law

Plaintiff filed an action against his former employer, the Attleboro Housing Authority (AHA), for alleged violations of the Wage Act, claiming (1) the AHA intentionally misclassified his position, thereby failing to pay him the wages to which he was entitled; and (2) the AHA terminated him in retaliation for complaining about the nonpayment of earned wages. The jury rendered a verdict in favor of Plaintiff on both claims and awarded damages against the AHA. The parties then filed numerous posttrial motions, to no avail. The Supreme Judicial Court affirmed, holding (1) the superior court had subject matter jurisdiction over Plaintiff’s claims under the Wage Act; (2) reinstatement to employment is not an available remedy for violations of the Wage Act; and (3) the trial judge did not abuse his discretion in denying Plaintiff’s motion for a new trial on damages or, in the alternative, for additur. View "Fernandes v. Attleboro Housing Auth." on Justia Law

Following a jury trial, Defendant was convicted of distributing cocaine and doing so in a school zone. Defendant appealed. While the appeal was pending, the school zone statute was amended to reduce the radius of the school zone. The appeals court affirmed Defendant’s convictions, concluding that the amendment did not have retroactive effect. The Supreme Judicial Court affirmed, holding that the Legislature did not intend to grant new trials to defendants who already had been convicted after the effective date of the amendment, and therefore, the amendment did not entitle Defendant to a new trial on his conviction of a school zone violation. View "Commonwealth v. Thompson" on Justia Law