Justia Massachusetts Supreme Court Opinion Summaries

After Defendant was indicted on murder charges, Defendant filed a motion to suppress evidence of cell site location information (CSLI) associated with the cellular phone he was using because the CSLI was obtained without a valid search warrant based on probable cause. The superior court granted the motion to suppress, concluding that Defendant’s rights under article 14 of the Massachusetts Declaration of Rights were violated because, although the Commonwealth had obtained the CSLI from Defendant’s cellular servicer provider pursuant to a valid court order under the Federal Stored Communications Act (SCA), the Commonwealth’s access to the CSLI constituted a search within the meaning of article 14. The Supreme Court agreed with the motion judge, holding that although the CSLI in this case was a business record of Defendant’s cellular servicer provider, Defendant had a reasonable expectation of privacy in it, and, under the circumstances, the warrant requirement of article 14 applied. Remanded to allow the Commonwealth to present evidence that the affidavit in support of its application for an order under the SCA demonstrated probable cause for the CSLI records. View "Commonwealth v. Augustine " on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on the theories of deliberate premeditation, extreme atrocity or cruelty, and felony-murder. The Supreme Court affirmed Defendant’s convictions, holding, inter alia, that (1) the motion judge did not err in denying Defendant’s motion to suppress his interview at a house of correction or Defendant’s motion to suppress the fruits of a search of his girlfriend’s home; (2) it was error to allow the Commonwealth’s fingerprint expert to make certain statements during her testimony, but the error did not create a substantial likelihood of a miscarriage of justice; (3) the absence of an instruction to the jury that they must unanimously agree on the predicate felony caused no prejudice to Defendant; and (4) the judge did not err in instructing the jury that the crimes of armed robbery and home invasion are “inherently dangerous to human life.” View "Commonwealth v. Wadlington" on Justia Law

After a jury trial, Defendant was convicted of armed robbery. Defendant appealed from his conviction and from the revocation of his probation that resulted from the conviction, challenging the sufficiency of the evidence identifying him as the perpetrator. The Supreme Court affirmed the conviction and concluded that there was no error in the revocation of Defendant’s probation, holding (1) the evidence was sufficient to support Defendant’s conviction; (2) the prosecutor did not misstate the evidence in her closing argument; and (3) the judge who presided at Defendant’s probation revocation hearing did not violate Defendant’s due process rights by denying Defendant’s requests to present additional evidence as to whether he committed the robbery. View "Commonwealth v. Joyner" on Justia Law

At issue in this appeal was Eaton v. Fed. Nat’l Mortgage Ass’n, which held that a foreclosure by power of sale is invalid unless a foreclosing party holds the mortgage and also holds either the underlying mortgage note or acts on behalf of the note holder. In the instant case, Plaintiffs defaulted on their mortgage payments, and Mortgage Electronic Registration Systems (MERS) sought to foreclose on the property. Plaintiffs filed a complaint against MERS claiming that MERS did not have standing to initiate foreclosure proceedings because it was not the holder of the promissory note or an authorized agent of any note holder. The superior court dismissed the complaint. Before Plaintiffs’ appeal was heard, the Supreme Court decided Eaton. The Supreme Court subsequently vacated the dismissal of Plaintiffs’ claim alleging a lack of authority to foreclose, holding (1) Eaton applies to cases, such as the instant case, that preserved the issue presented in Eaton and that were pending on appeal as of June 22, 2012; and (2) therefore, Plaintiffs’ complaint should not have been dismissed for failure to state a claim on the grounds that MERS lacked the authority to foreclose. Remanded. View "Galiastro v. Mortgage Elec. Registration Sys., Inc." on Justia Law

After a jury trial, Defendant was found guilty of deliberately premeditated murder in the first degree and sentenced to life imprisonment without the possibility of parole. Defendant was sixteen years old at the time of the murder. Defendant appealed, raising several allegations of error. The Supreme Court (1) affirmed Defendant’s convictions, holding that the motion judges and trial judge did not commit reversible error or abuse their discretion in their rulings and that Defendant’s counsel did not provide ineffective assistance; but (2) remanded the case to the superior court for resentencing, holding that, pursuant to the Court’s decision in Diatchenko v. Dist. Attorney interpreting the U.S. Supreme Court’s decision in Miller v. Alabama, Defendant was eligible for parole in accordance with the terms of Mass. Gen. Laws ch. 127, 133A. View "Commonwealth v. Ray" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree. During jury empanelment, the court room was closed to all members of the public, including Defendant’s family. After the Supreme Court’s ruling in Commonwealth v. Cohen, which held that the right to a public trial extended to jury empanelment, Defendant filed a motion for a new trial, asserting that the closure of the court room during his trial was structural error requiring reversal. The motion judge denied the motion, concluding that the seventy-nine minute closure was de minimis. The Supreme Court affirmed on other grounds, holding (1) the closure of a court room for the entire empanelment process is not de minimis, but Defendant waived his right to a public trial where his counsel was aware of the closure and did not object; and (2) counsel’s failure to object did not constitute ineffective assistance of counsel. View "Commonwealth v. Morganti" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on theories of deliberate premeditation and felony-murder. The Supreme Court affirmed Defendant’s convictions, holding (1) the motion judge correctly denied Defendant’s motions for a new trial based on Defendant’s assertions that newly discovered evidence called into question the trial testimony of two of the Commonwealth’s witnesses, and the motion judge did not abuse her discretion in denying Defendant’s requests for posttrial discovery; and (2) the trial judge did not commit prejudicial error in failing to give a specific instruction on witness credibility and in making certain evidentiary rulings. View "Commonwealth v. McGee" on Justia Law

In 2004, after a jury trial, Defendant was convicted of murder in the second degree. During jury empanelment, the court officers closed the court room to all members of the public, including Defendant’s family and friend. In 2008, after Defendant unsuccessfully filed a motion for a new trial and unsuccessfully appealed, Defendant filed a second motion for new trial, claiming that the closure of the court room was structural error requiring reversal. On remand, the motion judge denied the motion, concluding that the brief closure of the court room for jury empanelment was de minimis. The Supreme Court affirmed the denial of Defendant’s motion for new trial but on other grounds, holding (1) although the closure of the court room for the entire empanelment process was not de minimis, Defendant waived his right to a public trial where his experienced trial counsel was aware that the court room was routinely closed to spectators during the jury empanelment process and did not object; and (2) counsel’s failure to object did not deprive Defendant of the effective assistance of counsel. View "Commonwealth v. Alebord" on Justia Law

After a jury trial, George Labadie and Susan Carcieri, the latter of whom was employed by a federal credit union, were convicted of violating Mass. Gen. Laws. ch. 266, 52 for embezzling a “bank.” At issue on appeal was whether an employee of a federal credit union may be found guilty under section 52 of embezzlement of the credit union’s funds. The Supreme Court reversed and vacated Defendants’ convictions, holding (1) because the Commonwealth must prove under section 52 that the victim was a “bank” and because a federal credit union is not a “bank” as defined in Mass. Gen. Laws ch. 167, 1, Defendants were entitled to judgments of acquittal on this charge; (2) larceny by embezzlement is a lesser included offense of embezzlement of a bank, and federal preemption doctrine does not bar state prosecution of a federal credit union employee for larceny by embezzlement; and (3) the jury’s verdicts demonstrated that the jurors found Defendants guilty of the required elements of the lesser included offense of larceny by embezzlement. Remanded for entry of convictions of larceny by embezzlement. View "Commonwealth v. Labadie" on Justia Law

After a jury trial, Defendant was convicted of murder and related firearm charges. The appeals court affirmed. Defendant appealed, arguing that the trial court erred in denying his motion to suppress statements he made to the police during an interview at the police station. The Supreme Court affirmed, holding that the trial court did not err in admitting the statements where (1) because Defendant’s claimed invocations of the right to counsel were made before the interrogation became custodial, Defendant did not effectively invoke that right; (2) the totality of the circumstances supported the conclusion that Defendant’s statements were voluntary; and (3) even if Defendant did not validly waive his Miranda rights before making statements during the custodial portion of the interview, the admission of those statements was harmless beyond a reasonable doubt. View "Commonwealth v. Molina" on Justia Law