Justia Massachusetts Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of first degree murder on a theory of felony-murder and aggravated rape. The conviction of murder was affirmed on appeal and the conviction of aggravated rape was vacated as duplicative. Since 2002, Defendant unsuccessfully sought to obtain DNA testing of the physical evidence that was used to support the expert opinion evidence introduced at trial. In 2012, Defendant filed a motion for DNA testing pursuant to Mass. Gen. Laws ch. 278A, 3, asserting that he was factually innocent of the crimes for which he was convicted and that DNA testing could establish the identity of a third party who contributed to seminal fluid found in the victim’s vagina and clothes and “may wholly exonerate” him. The motion judge denied Defendant’s motion. The Supreme Court reversed, holding that the motion judge applied an incorrect standard in denying Defendant’s motion for DNA testing and that the motion met the requirements of Mass. Gen. Laws ch. 278A, 3. Remanded. View "Commonwealth v. Wade" on Justia Law

After a probation revocation hearing, a district court judge found that Defendant had violated the conditions of his probation and revoked Defendant's probation. On appeal, Defendant argued, among other things, that the judge made no separate finding as to good cause for proceeding without a witness with personal knowledge of the evidence presented, as required by Rule 6(b) of the District Court Rules for Probation Violation Proceedings. The Supreme Court affirmed, holding (1) the hearing comported with due process because the hearsay testimony on which the judge relied was substantially reliable and trustworthy; (2) Rule 6(b) of the District Court Rules of Probation Violation Proceedings is not to be construed as requiring more than is constitutionally mandated, and due process does not require, when the hearsay is substantially reliable, separate proof as to good cause; and (3) there was no improper interference by the office of the district attorney with the probation department’s conduct of the hearing that would give rise to a violation of article 30 of the Massachusetts Declaration of Rights. View "Commonwealth v. Bukin" on Justia Law

Defendant, his brother, his sister-in-law, and his cousin worked together in a tiling business in Oklahoma. All four individuals were hired to install tile in a fast-food restaurant under construction in Clinton. While working on the job, Defendant stabbed and killed the general manager with no apparent provocation or motive. The Supreme Court affirmed, holding (1) the trial court did not err in denying Defendant’s motion to suppress statements Defendant made to the police; (2) the joinder of the firearms charges with the murder charge for trial did not prejudice Defendant; (3) the admission of certain hearsay evidence at trial did not prejudice Defendant; (4) the trial court did not err in denying Defendant’s first motion for a new trial without an evidentiary hearing; and (5) trial counsel was not ineffective for failing to pursue a defense of lack of criminal responsibility based on evidence that Defendant may have been suffering from a spontaneous recurrence of methamphetamine-induced psychosis at the time of the stabbing. View "Commonwealth v. Spray" on Justia Law

On April 12, 2010, U.S. Bank National Association initiated a summary process action against Defendant, seeking to evict him from property he owned following the property’s sale to the Bank at a foreclosure auction. On May 25, 2012, a judge entered judgment in favor of the Bank for possession. Defendant appealed, arguing that the foreclosure sale was void because the notice of his right to cure a default did not satisfy the provisions of Mass. Gen. Laws ch. 244, 35A, which gives a mortgagor of residential real property a ninety-day right to cure a payment of default before foreclosure proceedings may be commenced. The Supreme Judicial Court affirmed, holding (1) section 35A is not one of the statutes relating to the foreclosure of mortgages by the exercise of a power of sale, and (2) that being the case, and given the deficiencies in the steps Defendant took to obtain relief, Defendant was precluded from challenging the Bank’s compliance with section 35A in this summary process action. View "U.S. Bank Nat'l Ass'n v. Schumacher" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on a theory of deliberate premeditation and of unlawful possession of a firearm. The Supreme Judicial Court affirmed the order denying Defendant’s motion to suppress identification evidence and affirmed Defendant’s convictions, holding that the trial judge did not err in (1) denying Defendant’s motion to suppress, as the police had good reason to conduct a showup identification procedure, and Defendant did not meet his burden of showing that he was subjected to a showup identification procedure that was unnecessarily suggestive; (2) admitting into evidence surveillance videotape recordings; (3) limiting cross-examination of a witness on the issue of bias; (4) deciding not to discharge a juror; and (5) instructing the jury. View "Commonwealth v. Meas" on Justia Law

Plaintiff filed an application for an ex parte temporary restraining order under Mass. Gen. Laws ch. 209A, 4 against Defendant. A probate and family court judge issued a permanent abuse prevention order directing Defendant to refrain from abusing or contacting Plaintiff, to stay away from her residence, and to surrender any firearms or ammunition to the police department. Defendant did not challenge the permanent order on direct appeal. Twelve years later, Defendant later moved to terminate the permanent abuse prevention order. A judge denied Defendant’s motion. The Supreme Judicial Court affirmed, holding (1) a Defendant who seeks to terminate a permanent abuse prevention order must show, by clear and convincing evidence, that, as a result of a significant change in circumstances, it is no longer equitable for the order to continue because the protected party no longer has a reasonable fear of imminent serious physical harm; and (2) in light of the totality of the circumstances in this case, the judge did not abuse her discretion in denying Defendant’s motion. View "MacDonald v. Caruso" on Justia Law

After a jury trial, Defendant was convicted of two counts of murder in the first degree. The Supreme Judicial Court affirmed the convictions, holding that the trial judge (1) did not err in denying Defendant’s motion to suppress his statements to police; (2) did not deny Defendant’s Sixth Amendment right to a fair trial by denying Defendant’s motion for a change of venue; (3) did not err in denying the admission of certain “third-party culprit” evidence and Defendant’s request for a third-party culprit instruction at trial; and (4) did not abuse his discretion in excluding expert testimony regarding the phenomenon of false confessions. View "Commonwealth v. Hoose" on Justia Law

Defendant admitted to sufficient facts to warrant a finding of guilty for possessing a class B controlled substance. The substance was tested at the forensic drug lab at the William A. Hinton State Laboratory Institute. The lab issued a drug certificate identifying the substance as one containing cocaine, and the first signature on the drug certificate was Annie Dookhan’s. Dookhan, a chemist at the drug lab, was indicted on multiple counts of evidence tampering and obstruction of justice, among other charges, relating to her handling and testing of samples at the lab. Defendant moved to vacate his underlying guilty plea on the basis of Dookhan’s involvement in testing the substance found in Defendant’s possession. The motion judge granted Defendant’s motion to vacate his guilty plea. The Supreme Court vacated the order, holding (1) where Dookhan signed the certificate of drug analysis as either the primary or secondary chemist in Defendant’s case, Defendant was entitled to a conclusive presumption that Dookhan’s misconduct occurred in his case; and (2) in order to prevail on his motion, Defendant must demonstrate a reasonable probability that knowledge of Dookhan’s misconduct would have materially influenced his decision to tender a guilty plea. Remanded. View "Commonwealth v. Scott" on Justia Law

Defendant was charged with several drug-related offenses. The substances in plastic bags seized from Defendant were sent to the William A. Hinton State Laboratory Institute for testing and were determined to contain 5.19 grams of heroin. Annie Dookhan signed the certificate of drug analysis. Dookhan, a chemist at the Hinton drug lab, was subsequently indicted on several criminal charges relating to her handling and testing of samples at the Hinton drug lab. Defendant, who had admitted to sufficient facts to warrant findings of guilty on two of the counts for which he was charged, filed a motion to withdraw his guilty pleas due to Dookhan’s testing of the drug evidence. A judge denied Defendant’s motion. The Supreme Court vacated the judge’s denial of Defendant’s motion based on its opinion issued today in Commonwealth v. Scott, holding (1) Defendant was entitled to a conclusive presumption that Dookhan’s misconduct happened in his case, that such misconduct was egregious, and that its occurrence was attributable to the Commonwealth; and (2) in order to prevail on his motion, Defendant must demonstrate a reasonable probability that knowledge of Dookhan’s misconduct would have materially influenced his decision to tender a guilty plea. Remanded. View "Commonwealth v. Rodriguez" on Justia Law

While Defendant was a passenger on the Massachusetts Bay Transportation Authority (MBTA) trolley on two occasions, Defendant aimed the camera on his cellular telephone at the crotch areas of seated female passengers and secretly attempted to photograph a visual image of the area. The Commonwealth issued two criminal complaints charging Defendant under Mass. Gen. Laws ch. 272, 105(b) with attempting to commit the offense of photographing, videotaping, or electronically surveilling a “nude or partially nude person.” The municipal court judge denied Defendant’s motion to dismiss the complaints, and Defendant sought interlocutory review. The Supreme Court reversed the order denying Defendant’s motion to dismiss, holding that section 105(b), as written, does not apply to photographing persons who are fully clothed and, in particular, does not reach the type of “upskirting” that Defendant was charged with attempting to accomplish on the MBTA. View "Commonwealth v. Robertson" on Justia Law