Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed the judgment of a single justice of the court denying Petitioner's petition pursuant to Mass. Gen. Laws ch. 211, 3, holding that the single justice did not err or abuse her discretion in denying relief.In the petition at issue, Petitioner argued that the government took her property without due process. Specifically, Petitioner alleged that, throughout the underlying foreclosure process and a summary process action, Petitioner never had an evidentiary hearing or an opportunity to confront and cross-examine adverse witnesses. The single justice denied the petition without holding a hearing. The Supreme Judicial Court affirmed, holding that extraordinary relief was not warranted. View "Brown v. Federal National Mortgage Ass'n" on Justia Law

The Supreme Judicial Court declined to address the merits of these appeals challenging the Attorney General's (AG) decision denying Plaintiffs' initiative petition that would have instituted limits on contributions to independent expenditure political action committees, holding that the appeals were moot.The AG determined that the proposed law conflicted with the Massachusetts Declaration of Rights' right of free speech and, therefore, addressed an excluded subject under article 48. Ultimately, the AG concluded that the proposed limitation on campaign contributions was precluded under United States Supreme Court precedent. Plaintiffs appealed. Thereafter, the AG offered to agree to a stipulated order, but Plaintiffs refused to agree with the order. Before the Supreme Judicial Court, the AG argued that the appeals were moot because Plaintiffs did not gather the first round of signatures set forth in article 48. The Supreme Judicial Court dismissed the cases as moot, holding that Plaintiffs failed to meet the deadline to file additional signatures with the Secretary of the Commonwealth. View "Herrmann v. Attorney General" on Justia Law

The Supreme Judicial Court vacated the order of the motion judgment dismissing indictments against Derrick Gentry-Mitchell and Joseph Sullivan, Springfield police department officers, charging them with misleading investigators, holding that the indictments did not violate article 12 of the Declaration of Rights of the Massachusetts Constitution.In dismissing the indictments charging misleading investigators, the motion judge, citing Commonwealth v. Barbosa, 421 Mass. 547 (1995), concluded that the indictments presented the possibility that Defendants might be convicted of a felony offense without first being indicted of the same by a grand jury because the indictments charged multiple acts in a single count. The Supreme Judicial Court reversed and remanded this case for further proceedings, holding (1) the indictments charged the essential crime of willfully misleading investigators to impeded the investigation of the same underlying event - the alleged assault of the victim by Defendants, who were off duty at the time; (2) the misleading statements constituted a continuing course of conduct actuated by a single, continuing impulse or intent, or general scheme to conceal that event; and (3) therefore, the indictments did not violate article 12. View "Commonwealth v. Sullivan" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of unlawful possession of a firearm, holding that the did not abuse its discretion in denying Defendant's motion for discovery, and there was no error in the proceedings below warranting a new trial.Defendant's conviction arose from a police investigation into a report of a shooting in a crowded residential area and the ensuing discovery of a firearm allegedly discarded by Defendant. Before trial, Defendant filed a motion for discovery of police reports that he argued was relevant and material to the question of whether the investigation was motivated by race, in violation of his constitutional equal protection rights. The trial judge denied the motion, and Defendant was subsequently convicted. The Supreme Judicial Court affirmed, holding (1) there was no abuse of discretion in the denial of Defendant's motion for discovery; and (2) some of the prosecutor's remarks during closing argument were improper, but the remarks did not warrant a new trial. View "Commonwealth v. Cuffee" on Justia Law

The Supreme Judicial Court affirmed the denial of Defendant's motion to suppress evidence seized from his person during a stop and pat-frisk, holding that the new standard adopted in Commonwealth v. Long, 485 Mass. 711, 724-725 (2020), is applicable in the context of police investigations such as pedestrian stops in addition motor vehicle stops.Defendant was indicted on firearm-related charges after he was stopped by police officers while walking. In his motion to suppress, Defendant argued that the stop was unconstitutional because the officers lacked reasonable suspicion and because statistical evidence proved the officers were more likely to stop Black members of the community than individuals of other races. In addressing Defendant's equal protection challenge, the lower court presumed that this Court's standard for establishing an equal protection claim under the Massachusetts Declaration of Rights, which was adopted to provide a defendant a more accessible path to pursuing an equal protection claim in the context of a motor vehicle stop, applied equally to this pedestrian stop challenge. The Supreme Judicial Court affirmed, holding (1) the new standard adopted in Long is applicable in this case; and (2) the evidence supported the trial court's determination that the officers stopped Defendant to investigate his involvement in the shooting and not because of his race. View "Commonwealth v. Robinson-Van Rader" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court in this personal injury action against Philip Morris USA Inc., holding that Philip Morris was not entitled to relief on its allegations of error.Plaintiff, who smoked Marlboro brand cigarettes for several decades and was eventually diagnosed with lung cancer, brought this action. The jury returned a verdict for Philip Morris on Plaintiff's negligence and breach of warranty claims but found for Plaintiff on her civil conspiracy claims. The trial judge subsequently entered judgment for Plaintiff on her Mass. Gen. Laws ch. 93A claim. The Supreme Judicial Court affirmed, holding (1) the jury verdict against Philip Morris for civil conspiracy and the trial judge's finding of liability under Mass. Gen. Laws ch. 93A were supported by the evidence; (2) Philip Morris waived its argument regarding a contested jury instruction; and (3) the twelve percent pre- and post judgment statutory interest rates pass rational basis review and, thus, are constitutional. View "Greene v. Philip Morris USA Inc." on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court convicting Defendant of murder in the first degree on a theory of extreme atrocity or cruelty and declined to grant relief under Mass. Gen. Laws ch. 278, 33E, holding that Defendant was not entitled to relief on his claims of error.On appeal, Defendant argued that his motions for a required finding should have been allowed because there was insufficient evidence to support a finding that he was the perpetrator. The Supreme Judicial Court disagreed, holding (1) the Commonwealth met its burden to prove that there was sufficient evidence for the jury to find, beyond a reasonable doubt, that Defendant had killed the victim; and (2) the trial judge did not abuse her discretion in allowing the introduction of certain evidence. View "Commonwealth v. MacCormack" on Justia Law

The Supreme Judicial Court held that a closed case that ends in an acquittal, a no bill from a grand jury, or a finding of no probable cause by the court is not a record subject to a presumption of access under the First Amendment and that the Legislature clearly abrogated the common-law presumption of access with respect to these records by its plain language in Mass. Gen. Laws ch. 276, 100C.Defendant was arraigned on two counts of rape while armed with a firearm and other crimes. A jury acquitted Defendant on one count of rape while armed, assault with intent to rape, and carrying a firearm without a license and deadlocked on the remaining three counts, resulting in a mistrial. The Commonwealth ultimately filed a nolle prosequi. Defendant later brought his section 100C petition to seal his criminal record as to the counts on which he was acquitted and the courts for which the nolle prosequi was filed. A judge denied the petition. The Supreme Judicial Court remanded the case for further proceedings, holding that, regarding the counts in which the nolle prosequi was entered, the judge abused his discretion when weighing the relevant interests and factors. View "Commonwealth v. J.F." on Justia Law

The Supreme Judicial Court reduced Defendant's convictions of armed robbery while masked to unarmed robbery and vacated the judgment on the conviction of armed home invasion and set aside the verdict, holding that an instructional error created a substantial risk of a miscarriage of justice.Defendant was convicted, after a jury trial, of armed home invasion and armed robbery while masked. While the indictments were based on a theory of joint venture the jury were not instructed that the Commonwealth must prove that Defendant knew that at least one coventurer was armed and at least one coventurer was armed and masked. The Supreme Court held (1) the failure to provide these instructions was error; and (2) the error left the Court with a serious doubt whether the result of the trial might have been different had the jury been correctly instructed. View "Commonwealth v. Desiderio" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of two counts of two counts of murder in the first degree on the theory of premeditation as to Mark Greenlaw and Jennifer O'Connor and on the theory of extreme atrocity or cruelty as to O'Connor, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Judicial Court held (1) the trial judge did not abuse his discretion in denying Defendant's motion for a mistrial regarding the victim's fear of rape; (2) the prosecutor's statement during closing argument impermissibly appeal to the jury's sympathy, but the statement did not create a substantial likelihood of a miscarriage of justice; (3) the trial judge erred in failing to instruct the jury that it could consider voluntary ingestion of drugs in determining extreme atrocity or cruelty, but the error did not create a substantial likelihood of a miscarriage of justice; (4) the judge did not err in excusing juror number fifteen; (5) the indictment charging attempted burning of a dwelling was not defective; and (6) there was no error warranting relief under Mass. Gen. Laws ch. 278, § 33E. View "Commonwealth v. Doughty" on Justia Law