Justia Massachusetts Supreme Court Opinion Summaries

The case involved a defendant who was convicted by a jury in 2020 of murder in the first degree, armed robbery, larceny of a motor vehicle, and unlawful possession of a firearm. The events leading to the charges began when the defendant, his girlfriend, and the victim lived together in Florida, using proceeds from a house sale to fund hotel stays and drug purchases. After a falling out, the defendant and the victim traveled to Massachusetts, where tensions escalated over money. The defendant ultimately shot the victim in a Massachusetts park after a series of text messages and conversations indicating premeditation. The defendant admitted to the killing but claimed self-defense and mental impairment due to longstanding mental illness and substance use.The Superior Court conducted a twelve-day trial, after which the jury found the defendant guilty on all counts. The defendant was sentenced to life without parole for murder, with additional consecutive sentences for the other convictions. He appealed his convictions and filed a motion for a new trial, arguing ineffective assistance of counsel and prosecutorial misconduct. The trial judge, who also heard the motion for a new trial, denied the motion after evidentiary hearings, finding that counsel’s investigation into the defendant’s mental health history was sufficient and that the strategic decision not to introduce corroborating medical records was reasonable.The Supreme Judicial Court of Massachusetts reviewed the consolidated appeals. The court held that the trial judge did not abuse his discretion in denying the motion for a new trial. It found no substantial likelihood of a miscarriage of justice from counsel’s investigation or strategic decisions, and determined that the prosecutor’s conduct did not improperly shift the burden of proof or prejudice the defendant. The court affirmed the convictions for murder, armed robbery, and larceny, and the denial of the new trial motion. However, it vacated the firearm conviction due to insufficient evidence regarding licensure and remanded for further proceedings on that count. View "Commonwealth v. Noguera" on Justia Law

In this case, the defendant, a lawyer, was accused of delivering sixty-one orange strips containing Suboxone, a controlled substance, to an inmate at a county house of correction. The delivery was disguised as legal paperwork following instructions from another inmate. The strips were confiscated by officers who suspected they were Suboxone. Forensic testing was performed by analyst Dunlap, who concluded the strips contained Suboxone. Dunlap documented her procedures and results in her notes, but was no longer employed at the crime lab at the time of trial. Instead, LaBelle, a supervisor who had not participated in or observed the testing, reviewed Dunlap’s work and testified as a substitute expert, relaying Dunlap’s notes and offering her own opinion based on the case file.A jury in the Massachusetts Superior Court found the defendant guilty of unlawfully delivering a class B controlled substance to a prisoner. The Appeals Court affirmed the conviction, reasoning that LaBelle’s opinion was independent. After the United States Supreme Court decided Smith v. Arizona, the Supreme Court granted certiorari, vacated the Appeals Court’s judgment, and remanded for reconsideration in light of Smith. The Supreme Judicial Court of Massachusetts then transferred the case for review.The Supreme Judicial Court of Massachusetts held that the admission of LaBelle’s testimony violated the defendant’s Sixth Amendment right to confront witnesses. The Court found that LaBelle’s opinion was not independent, as it depended on the truth of Dunlap’s testimonial hearsay statements regarding the procedures and results of the testing. The Court concluded that this error was not harmless beyond a reasonable doubt and vacated the conviction, remanding for a new trial. The Court also held that its new rule applies prospectively to cases not yet final. View "Commonwealth v. Gordon" on Justia Law

An individual pleaded guilty to multiple sexual offenses committed against two girls, aged thirteen and fourteen, when he was eighteen years old. The offenses included several instances of rape and indecent assault. The individual had a history of psychological diagnoses, including autism spectrum disorder. After his conviction, the Sex Offender Registry Board (SORB) initially classified him as a level three sex offender, which would require the highest level of public notification. The individual challenged this classification, leading to a de novo hearing before a SORB hearing examiner.At the hearing, the examiner found by clear and convincing evidence that the individual posed a moderate risk of reoffense and a moderate degree of danger, resulting in a reclassification to level two. The examiner considered several statutory and regulatory factors, including the number of victims, the nature and location of the offenses, and the individual’s psychological profile. The examiner also considered the fact that the individual committed multiple offenses, including repeated offenses against one victim, as relevant to the degree of dangerousness. The examiner determined that Internet publication of the individual’s registration information would serve a public safety interest. The individual sought judicial review in the Massachusetts Superior Court, which affirmed the SORB’s decision.The Supreme Judicial Court of Massachusetts reviewed the case after transferring it from the Appeals Court. The court held that the SORB hearing examiner did not err in considering the individual’s multiple offenses as relevant to dangerousness under regulatory factor thirty-seven, even though such consideration is limited under factor two, which addresses risk of reoffense. The court also declined to find the application of factor thirty-seven unconstitutional due to a lack of empirical evidence, given the statutory mandate to consider the number of offenses. The court affirmed the classification as a level two offender and the requirement for Internet dissemination of registration information. View "Doe v. Sex Offender Registry Board" on Justia Law

A former state senator was indicted on two counts of using his official position to secure unwarranted privileges by directing his publicly funded Senate staff to perform campaign work for his 2018 and 2020 reelection efforts. The Senate president received anonymous complaints about this conduct, which led to a Senate ethics committee investigation. The committee found that the senator knowingly had his staff perform campaign and fundraising work during regular business hours, ignored repeated warnings that this was inappropriate, and violated Senate rules and likely state conflict-of-interest and campaign-finance laws. The committee recommended disciplinary measures, and the matter was referred to state ethics and campaign finance authorities, eventually resulting in criminal indictments after a grand jury investigation.A judge of the Massachusetts Superior Court denied the defendant’s motion to dismiss the indictments, which argued for legislative immunity under the Massachusetts Constitution and claimed that the prosecution violated separation of powers principles. The defendant also argued that the prosecutor improperly excluded a grand juror for alleged political bias without court approval. After the motion was denied, the defendant sought interlocutory review in the Supreme Judicial Court for Suffolk County under G. L. c. 211, § 3.The Supreme Judicial Court of Massachusetts held that interlocutory review of a denial of a motion to dismiss based on legislative immunity in a criminal case must be sought under G. L. c. 211, § 3, not through the doctrine of present execution. The court further held that the defendant was not immune from prosecution under either the state constitution’s speech or debate clause or separation of powers provisions. Additionally, while the prosecutor erred in excusing a grand juror for bias without judicial involvement, the defendant was not prejudiced, so dismissal was not warranted. The court affirmed the denial of the motion to dismiss and remanded for entry of judgment denying extraordinary relief. View "Tran v. Commonwealth" on Justia Law

In this case, a juvenile defendant was implicated in a home invasion and rape that occurred in Methuen, Massachusetts, in November 2018. The victim identified three intruders, and subsequent investigation led to the defendant’s arrest. After his arrest, police obtained a DNA sample from the defendant via a warrantless buccal swab, which the Commonwealth later conceded was unlawful. The resulting DNA evidence was suppressed. However, after the defendant was indicted as a youthful offender, the Commonwealth, relying on evidence independent of the suppressed DNA, successfully moved for a court order compelling a second, postindictment buccal swab. DNA evidence from this second swab was admitted at trial.The Essex County Division of the Juvenile Court Department initially heard the case. The judge suppressed the first DNA sample but granted the Commonwealth’s motion to compel the second sample, finding probable cause based on evidence unrelated to the initial, unlawful swab. At trial, the defendant was convicted by a jury of aggravated rape and other offenses. He was sentenced to a term of imprisonment and probation. The defendant appealed, challenging both the order compelling the second DNA sample and the jury instructions regarding “serious bodily injury” as an element of aggravated rape. The Supreme Judicial Court of Massachusetts transferred the case from the Appeals Court for review.The Supreme Judicial Court of Massachusetts held that the second, court-ordered buccal swab was lawfully obtained based on independent probable cause and was not tainted by the prior illegality, so the DNA evidence was properly admitted. The Court also found no error in the jury instructions. However, because the general verdict did not specify which aggravating theory the jury relied on, and only one theory was supported by sufficient evidence, the aggravated rape conviction was vacated and the case remanded for further proceedings. View "Commonwealth v. Carvajal" on Justia Law

A police officer in East Bridgewater observed two men riding a moped without helmets and initiated a traffic stop. The operator, John Pena, had a suspended license and an outstanding warrant, while the passenger, Erik Ferrara, also lacked a driver’s license. Unable to secure the moped, the officer arranged for it to be towed and conducted an inventory search, discovering a backpack in the storage compartment. Inside the backpack, the officer found a loaded handgun with its serial number removed, along with Ferrara’s identification card and other personal items. Ferrara was arrested and later claimed ownership of some items in the backpack but denied knowledge of the firearm.In the Brockton Division of the District Court Department, Ferrara moved to suppress the evidence from the search, arguing that the impoundment and inventory search violated departmental policy. The motion was denied, and Ferrara proceeded to trial, where a jury found him guilty of carrying a firearm without a license, carrying a loaded firearm without a license, and defacement of a firearm’s serial number. Other charges were dismissed at the Commonwealth’s request. Ferrara appealed, challenging the denial of his suppression motion and the sufficiency of evidence for the defacement conviction.The Supreme Judicial Court of Massachusetts reviewed the case. It held that the motion to suppress was properly denied, finding the impoundment and inventory search consistent with departmental policy and constitutional requirements. However, the court vacated Ferrara’s firearm possession convictions and ordered a new trial, as the jury had not been properly instructed that the Commonwealth must prove beyond a reasonable doubt that Ferrara did not possess a firearms license. The court also reversed the conviction for intentional defacement of a firearm, concluding that the evidence was insufficient to support that charge under the theory presented to the jury. View "Commonwealth v. Ferrara" on Justia Law

In the early morning of July 7, 2012, a group of men, including the defendant and his cousin, forcibly entered a home in Billerica, Massachusetts, intending to commit robbery. Several were armed. During the attempted robbery, a struggle broke out between the intruders and the residents. The defendant was struck with a tea kettle, and in the ensuing chaos, one of the residents was fatally shot. The perpetrators fled without obtaining any money. The defendant later sought medical treatment for injuries sustained during the incident.After being identified as a suspect, the defendant was interviewed by police on multiple occasions. He initially denied involvement but later made incriminating statements after being shown a portion of his cousin’s recorded interview implicating him. The defendant moved to suppress these statements, arguing they were obtained in violation of his Miranda rights and were involuntary. The Superior Court judge denied the motion to suppress, finding no violation. At trial, the defendant was convicted by a jury of felony-murder in the first degree and armed home invasion. The attempted armed robbery conviction was dismissed as duplicative. The defendant appealed, challenging the denial of his motion to suppress, the jury instructions on armed home invasion, and seeking relief under G. L. c. 278, § 33E.The Supreme Judicial Court of Massachusetts reviewed the case. It held that the defendant’s statements were not the product of custodial interrogation prior to Miranda warnings, and that his subsequent waiver of rights and statements were voluntary. The Court also found that, although the trial judge’s jury instruction on armed home invasion contained a minor legal error, it did not create a substantial likelihood of a miscarriage of justice. Finally, the Court declined to grant relief under G. L. c. 278, § 33E, finding no basis to disturb the verdict. The convictions were affirmed. View "Commonwealth v. Estabrook" on Justia Law

A dispute arose over public access to a portion of Estabrook Road in Concord, Massachusetts, which runs through land owned by various private parties, land trusts, and Harvard College. The road consists of a northern section, which was formally laid out by county authorities in 1763, and a southern section, for which no direct layout records exist but which connects to the northern section and an undisputed public way. The abutting landowners sought to bar public access, arguing that the southern section was never a public way and that a 1932 discontinuance order by county commissioners converted the road into a private way, extinguishing public rights. The town of Concord contended that both sections were public ways and that the 1932 order only ended the town’s maintenance obligation, not public access.The Land Court, after a bench trial, found that both the northern and southern disputed sections had been established as public ways, the latter based on circumstantial evidence such as historical use, maintenance, and references in town records. The court also concluded that the 1932 discontinuance under G. L. c. 82, § 32A, terminated only the town’s duty to maintain the road, not the public’s right to use it. The Appeals Court affirmed, modifying the judgment to clarify that both sections were public ways prior to 1932 and that public access was not terminated by the 1932 order.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the lower courts’ decisions. It held that the Land Court did not err in finding, based on both direct and circumstantial evidence, that the disputed sections were public ways by 1763. The Court further held that the 1932 discontinuance under § 32A relieved the town of maintenance obligations but did not extinguish the public’s right of access to the road. The judgment as modified by the Appeals Court was affirmed. View "Town of Concord v. Rasmussen" on Justia Law

The case concerns an individual who, after responding to an online advertisement posted by an undercover police officer posing as two twenty-year-old women, learned that the supposed women were actually fifteen years old. Despite this, he continued to arrange a meeting for sexual services in exchange for money, drove from Massachusetts to Rhode Island, and was arrested upon arrival. He was found in possession of cocaine and ultimately pleaded nolo contendere in Rhode Island to indecent solicitation of a child, receiving a suspended sentence and probation. The individual also had a prior history of criminal justice involvement, including violations of abuse prevention orders and drug-related charges.Following his conviction, the Massachusetts Sex Offender Registry Board (SORB) issued a preliminary determination classifying him as a level two sex offender. After a de novo hearing, a SORB hearing examiner confirmed this classification, applying several risk-elevating factors, including targeting children, stranger victims, substance abuse, criminal justice contact, hostility towards women, and number of victims. The individual challenged the classification in the Massachusetts Superior Court, arguing that the decision was arbitrary, capricious, and unsupported by substantial evidence, particularly contesting the application of certain risk factors. The Superior Court denied his motion for judgment on the pleadings and affirmed the SORB decision.The Supreme Judicial Court of Massachusetts reviewed the case after transferring it from the Appeals Court. The court held that the hearing examiner did not abuse discretion in applying or weighing the challenged risk factors. However, the court found that the hearing examiner’s written decision was ambiguous regarding whether the individual’s information should be disseminated to the public, which is essential for determining the proper classification level. As a result, the Supreme Judicial Court vacated the Superior Court’s judgment and remanded the matter to SORB for a clear, written conclusion on both the need for dissemination and the classification level. View "Doe, Sex Offender Registry Board No. 528042 v. Sex Offender Registry Board" on Justia Law

A child was born in Connecticut in July 2024 to parents who both resided in Connecticut at the time of the birth. The mother, who had previously lived in Massachusetts and had a long history with the Massachusetts Department of Children and Families (DCF), moved to Connecticut several months before the birth, enrolling in a Connecticut healthcare program and living in a domestic violence shelter there. The father had also been living in Connecticut. The Massachusetts DCF, concerned about the child’s welfare due to the mother’s history and a recent domestic violence incident involving the father, arranged to take emergency custody of the child at the Connecticut hospital immediately after birth.Two days after the child’s birth, the Massachusetts DCF filed a care and protection petition in the Hampden County Division of the Juvenile Court Department, seeking temporary custody. The Juvenile Court granted temporary custody to the department without determining the basis for jurisdiction. Later, after hearings, a Juvenile Court judge found that Massachusetts had default jurisdiction under the Massachusetts Child Custody Jurisdiction Act (MCCJA), and subsequently, after joint conferences with a Connecticut judge, concluded that Massachusetts was the appropriate forum because Connecticut had declined jurisdiction. The parents and the child sought interlocutory appeal, and the Appeals Court allowed it. The Supreme Judicial Court of Massachusetts then transferred the case on its own initiative.The Supreme Judicial Court of Massachusetts held that the Juvenile Court lacked jurisdiction under the MCCJA because Connecticut was the child’s “home state,” as the child lived there from birth with the parents. The Court found that Massachusetts did not have default, emergency, or appropriate forum jurisdiction, as Connecticut had not declined jurisdiction before the Massachusetts court issued custody orders. The Supreme Judicial Court remanded the case for dismissal due to lack of jurisdiction. View "Care and Protection of Faraj" on Justia Law