Justia Massachusetts Supreme Court Opinion Summaries

The case revolves around a defendant, Nelson Barros, who was charged with one count of assault and battery on a household member. Barros, a noncitizen, chose to represent himself during his arraignment and plea hearing. He signed a form acknowledging he had waived his right to counsel. The judge informed him of his right to counsel and confirmed that Barros wished to represent himself. However, the judge did not conduct any further inquiry to determine whether Barros' waiver of counsel was made knowingly and intelligently. Barros admitted to sufficient facts to warrant finding him guilty and was placed on one year of probation. Later, Barros was detained by Immigration and Customs Enforcement officers due to his admission to sufficient facts to find him guilty of assault and battery on a household member.The lower courts denied Barros' motions to withdraw his plea. The motion judge, who was not the plea judge, found that Barros' waiver of the right to counsel was knowing and voluntary. Barros appealed, and the Supreme Judicial Court granted his application for direct appellate review.The Supreme Judicial Court of Massachusetts affirmed the lower court's decision but on alternate grounds. The court held that Barros' waiver of counsel was invalid, in violation of his right to counsel under art. 12 of the Massachusetts Declaration of Rights. The judge did not conduct an adequate inquiry to determine whether Barros' waiver of counsel was made knowingly and intelligently. However, Barros did not challenge this waiver of counsel in his first motion to withdraw his admission to sufficient facts. Therefore, he must establish a substantial risk of a miscarriage of justice to prevail on appeal. The court concluded that Barros did not raise a serious doubt that the result of the proceeding might have been different had his waiver of counsel been adequately informed. View "Commonwealth v. Barros" on Justia Law

The case involves New England Auto Max, Inc., and others (the defendants), who are involved in a civil action where they unsuccessfully moved to dismiss the action for exceeding the $50,000 limit. The defendants then petitioned the Supreme Judicial Court for extraordinary relief, which was denied on the grounds that the defendants had an alternate avenue of appellate relief. The defendants appealed this decision.The case was initially heard in the District Court, where the defendants' motion to dismiss the action for exceeding the $50,000 limit was denied. The defendants then petitioned the Supreme Judicial Court for extraordinary relief, which was denied by a single justice on the grounds that the defendants had an alternate avenue of appellate relief. The defendants appealed this decision to the Supreme Judicial Court.The Supreme Judicial Court held that the single justice did not err or abuse his discretion in denying relief to the defendants. However, the court decided to exercise its discretion to address the question of law presented by the defendants. The court held that the defendants had a right to an interlocutory appeal to the Appellate Division of the District Court on the question of law they presented before the court. The court also concluded that the District Court judge erred in holding that the court could not look beyond a plaintiff's initial statement of damages in assessing whether there is a reasonable likelihood that recovery by the plaintiff will exceed $50,000. The case was remanded to the county court for entry of an order vacating the denial of the defendants' motion to dismiss and remanding to the District Court for further proceedings consistent with the court's opinion. View "New England Auto Max, Inc. v. Hanley" on Justia Law

The case involves Brandyn Lepage, who was convicted of first-degree murder on the theory of felony-murder. Lepage shot and killed Aja Pascual in her car on September 29, 2012. The police obtained call logs from the victim's phone, which showed that Lepage had called the victim shortly before her death. The police also obtained Lepage's cell phone records, including call detail records, historical cell site location information (CSLI), and ping data, without a warrant. Lepage appealed his conviction and the denial of his motion for a new trial, arguing that the police illegally obtained his cell phone records.The Superior Court Department had denied Lepage's pretrial motions to suppress the cell phone records. The court found that the police did not illegally obtain Lepage's call detail records and did not use the CSLI or ping data in the manner Lepage alleged. Lepage's motion for a new trial was also denied by the same judge who had previously denied his motions to suppress.The Supreme Judicial Court affirmed Lepage's conviction of murder in the first degree and the denial of his motion for a new trial. The court concluded that Lepage did not have a reasonable expectation of privacy in his call detail records, and therefore the police did not need a warrant to obtain this information. The court also found that the police did not use Lepage's CSLI or ping data to secure evidence against him. Therefore, the court concluded that there was no violation of Lepage's constitutional rights. However, the court vacated Lepage's conviction of unlawful possession of a firearm and remanded for a new trial on that indictment. View "Commonwealth v. Lepage" on Justia Law

The case revolves around Quasim Hastings, a prisoner convicted of second-degree murder in 2004 and eligible for parole consideration. Hastings, diagnosed with a mental disability, is entitled to a parole hearing that provides him with protections under the Massachusetts Constitution and Federal and State statutes prohibiting discrimination based on disability. Prior to a 2023 parole hearing, Hastings' counsel filed a motion for funds to retain a forensic psychologist and a social services advocate to assist with preparing a prerelease plan. While the motion for a forensic psychologist was approved, the request for a social services advocate was denied by a different Superior Court judge, who reasoned that the indigency statute limits his authority to approve funds to pending proceedings or appeals in any court.The judge's denial of the motion for funds was reported to the Appeals Court, and Hastings's application for direct appellate review was granted by the Supreme Judicial Court. The Supreme Judicial Court concluded that Hastings's motion for funds to retain a social services advocate implicates his State constitutional right to reasonable disability accommodations. Therefore, the constitutionally mandated exception to the indigency statute applies, and the order denying Hastings's motion for funds was reversed. The court held that a judge has the discretion to allow a motion for funds to pay for expert assistance as reasonably necessary to safeguard the indigent prisoner's constitutional rights prohibiting discrimination on the basis of disability. View "Commonwealth v. Hastings" on Justia Law

The defendant, Warren W. Dunn, was charged with two counts of possession of child pornography and two counts of possession of child pornography as a subsequent offense. The charges were based on evidence found in his apartment during a search conducted under a warrant. The warrant was issued based on an affidavit by a state trooper, who had received a report from the National Center for Missing and Exploited Children (NCMEC) about two images flagged as potential child pornography by Microsoft. The trooper described the images in his affidavit but did not attach them. The defendant had previously been arrested in 2007 for possession of child pornography.In the Superior Court, the defendant filed motions to suppress the evidence and for a hearing on the affidavit supporting the search warrant. The court denied both motions. The defendant then pleaded guilty to all charges, preserving his right to appeal the denials of his motions.The Supreme Judicial Court of Massachusetts affirmed the lower court's decisions. The court held that, although attaching the photographs or providing a more detailed description would have been preferable, the affidavit as a whole was sufficient to establish probable cause for the search warrant. The court also held that the motion judge did not abuse her discretion in concluding that the defendant failed to demonstrate that the trooper's descriptions of the images were false. The court declined to create a new rule requiring magistrates to personally view allegedly lewd images before issuing search warrants. View "Commonwealth v. Dunn" on Justia Law

The case involves a juvenile who was apprehended with firearms and ammunition and charged with various offenses. After being arraigned as a youthful offender, the juvenile was diagnosed with several information-processing disorders, including a language-based learning disorder. The juvenile was found incompetent to stand trial but capable of attaining competency in the future. However, after two competency proceedings, the juvenile was again found incompetent to stand trial, and the judge declined to make a definite finding on whether the juvenile could attain competency in the foreseeable future. The juvenile filed motions to dismiss the charges under the statute governing the dismissal of pending charges against incompetent persons, but these motions were denied.The Supreme Judicial Court of Massachusetts was tasked with deciding three main issues. First, whether the mental health code provides for the remediation of incompetent juveniles, particularly those incompetent but not mentally ill. Second, whether, in the absence of remediation programming under the mental health code, the ability to create and mandate remediation programming is within the scope of the Juvenile Court's inherent authority. Lastly, whether the pending charges against the juvenile can be dismissed "in the interest of justice."The court held that the mental health code does not provide for the remediation of juveniles found incompetent for reasons other than mental illness. It also rejected the argument that the ability to create and mandate remediation programming for incompetent juveniles falls within the purview of the Juvenile Court's inherent authority, stating that the creation of remediation programming falls within the purview of the Legislature. Regarding the dismissal of charges, the court remanded the matter to the Juvenile Court for further findings on whether the juvenile poses a present danger to the community. View "Makis M. v. Commonwealth" on Justia Law

The case involves a group of petitioners who challenged a trial court's decision to establish a 200-foot buffer zone around the Norfolk County Superior Court House during the trial of a high-profile murder case. The buffer zone was created in response to protests and demonstrations near the courthouse, which the Commonwealth argued could jeopardize a fair trial. The petitioners, who sought to intervene in the trial court proceedings to oppose the buffer zone, argued that it infringed on their First Amendment rights.The trial judge allowed the Commonwealth's motion for a buffer zone, albeit reducing it from the requested 500 feet to 200 feet. The judge denied the petitioners' motion to intervene, arguing that the buffer zone was necessary to ensure a fair trial and to protect jurors and witnesses from potential intimidation or harassment. The petitioners subsequently filed petitions for relief from both the buffer zone order and the denial of their motion to intervene.The single justice of the Supreme Judicial Court denied the petitions, concluding that the trial judge's decision was an ordinary procedural ruling and did not warrant the court's extraordinary power of general superintendence. The single justice also found that the buffer zone met the "reasonable restriction" requirements, being content-neutral, narrowly tailored to serve a significant governmental interest, and leaving open ample alternative channels for communication.The Supreme Judicial Court affirmed the single justice's decision, rejecting the petitioners' argument that the buffer zone order should be analyzed under strict scrutiny as a prior restraint on speech. The court found that the buffer zone did not forbid protestors from expressing their message, but merely restricted where they could do so. The court also noted that the petitioners failed to provide sufficient evidence to establish that the buffer zone extended onto public sidewalks or other areas constituting a public forum. View "Spicuzza v. Commonwealth" on Justia Law

The case revolves around a public records request made by Eric Mack, whose brother, Anthony Harden, was fatally shot by police. Mack sought records related to the shooting under Massachusetts public records law. The district attorney's office, which had investigated the shooting, argued that the requested records were exempt from disclosure under three exemptions: the privacy exemption, the policy deliberation exemption, and the investigatory exemption. The Superior Court granted Mack's motion for summary judgment, ordering the disclosure of the requested documents with minor exceptions. The district attorney's office appealed.The Supreme Judicial Court of Massachusetts affirmed in part, reversed in part, and remanded the case. The court held that the privacy exemption did not apply to the requested records because they related to a law enforcement misconduct investigation. The court also held that the policy deliberation exemption did not apply to the draft of the preliminary district attorney's office report, except for the "Applicable Laws" and "Conclusion" sections, which could be redacted. The court remanded the case to the Superior Court to determine whether the investigatory exemption applied to the videotaped public employee interviews and the investigator's interview questions. The court rejected the district attorney's office's argument that the Massachusetts Peace Officer Standards and Training Commission had exclusive authority to release officers' names. View "Mack v. District Attorney for the Bristol District" on Justia Law

The case involves a professional photographer who sexually exploited a minor. The defendant initially contacted the victim through a social networking site and began communicating with her through various means, eventually soliciting and receiving explicit images of the victim. The defendant also met the victim in person and sexually abused her. After the victim's parents reported the exploitation to the police, an investigation was launched. The police seized a computer tower, an external hard drive, and other items from the defendant's former residence. A forensic examination of the hard drives revealed explicit images of the victim, communications between the defendant and the victim, and hundreds of images of unidentified females in various stages of undress.The defendant was indicted on multiple counts, including aggravated rape of a child and enticement of a minor. He pleaded guilty to all charges, except for the eight counts of aggravated rape of a child, where he pleaded guilty to the lesser included offense of statutory rape. After being sentenced, the defendant filed a motion for the return of the seized property. The Commonwealth opposed the return of the property, arguing that it was in the "public interest" to destroy the devices. The Superior Court denied the defendant's request for the return of certain property.The Supreme Judicial Court of Massachusetts granted an application for direct appellate review. The court concluded that the procedural requirements set forth in G. L. c. 276, §§ 4 to 8, must be followed before a forfeiture decree may be issued under G. L. c. 276, § 3. The court vacated the Superior Court orders denying the return of certain property to the defendant and remanded the case for further proceedings consistent with its opinion. View "Commonwealth v. James" on Justia Law

The case revolves around Outfront Media LLC (Outfront), a company that entered into a contract with the Massachusetts Bay Transportation Authority (MBTA) to advertise on outdoor signs owned by the MBTA. The city of Boston assessed real estate tax for fiscal year 2021 on Outfront for the signs. Outfront sought an abatement of the tax, arguing that the signs were exempt from taxation under § 24. The city denied Outfront's claim for abatement, and Outfront appealed to the Appellate Tax Board (board), which upheld the tax assessment.The Appellate Tax Board upheld the city of Boston's tax assessment on Outfront Media LLC for the use of outdoor advertising signs owned by the Massachusetts Bay Transportation Authority (MBTA). Outfront had argued that the signs were exempt from taxation under § 24, but the board disagreed, leading to Outfront's appeal.The Supreme Judicial Court of Massachusetts affirmed the decision of the Appellate Tax Board. The court held that Outfront's use of the MBTA's outdoor advertising signs to post advertisements and generate advertising revenue constituted a "use" of the MBTA's property "in connection with a business conducted for profit" under § 24. The court distinguished such businesses from those merely providing a service for the MBTA such as a janitorial service. Therefore, Outfront used the signs within the meaning of § 24 and the decision of the board was upheld. View "Outfront Media LLC v. Board of Assessors of Boston" on Justia Law