Justia Massachusetts Supreme Court Opinion Summaries
Wallace v. Commonwealth
The Supreme Judicial Court affirmed the order of a single justice of the court denying Petitioner's petition filed pursuant to Mass. Gen. Laws ch. 211, 3, holding that nothing in Petitioner's petition required exercise of the court's extraordinary power of general superintendence.Petitioner, who was indicted for murder in the first degree and related offenses, filed a document entitled "Notice of Default and Opportunity to Cure re affidavit -- 'Writ of Quo Warranto' re Proof of Claim/Jurisdiction'" claiming that the courts of the Commonwealth lacked jurisdiction over him. The superior court judge denied the petition. Thereafter, Petitioner brought this petition seeking review. A single justice denied the petition. The Supreme Judicial Court affirmed, holding that the single justice was warranted in denying this Mass. Gen. Laws ch. 211, 3 petition. View "Wallace v. Commonwealth" on Justia Law
Posted in:
Criminal Law
Commonwealth v. Beatty
The Supreme Judicial Court affirmed Defendant's conviction of one count of murder in the first degree on the theories of deliberate premeditation, extreme atrocity or cruelty, and felony murder, holding that there was no prejudicial error or reason to grant relief under Mass. Gen. Laws ch. 278, 33E.Specifically, the Supreme Judicial Court held (1) the trial judge did not abuse his discretion in finding Defendant competent to stand trial over defense counsel's objections; (2) Defendant was not prejudiced by the jury instructions concerning the consequences of a verdict of not guilty due to lack of criminal responsibility; and (3) the jury were entitled to conclude that Defendant was criminally responsible, and this Court declines to reduce the degree of guilt, order a new trial, or grant other relief under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Beatty" on Justia Law
Posted in:
Criminal Law
Smiley First, LLC v. Dep’t of Transportation
In this case considering whether an easement (2018 easement) taken by eminent domain by the Department of Transportation (MassDOT) exceeded the scope of an easement taken in 1991 by the Department of Public Works (DPW), MassDOT's predecessor in interest, with respect to Plaintiff's land in South Boston (burdened land), the Supreme Judicial Court held that summary judgment was improperly granted for MassDOT.DPW's 1991 order of taking created an easement over the burdened land for purposes of constructing a haul road. In 2017, the Massachusetts Bay Transportation Authority began planning the construction of a test track on a portion of Plaintiff's land burdened by the 1991 easement. MassDOT recorded the 2018 confirmatory order of taking and then, contending that the taking merely confirmed that rights it held under the 1991 taking, refused to pay Plaintiff any compensation. Plaintiff responded with this litigation, and the superior court judge entered summary judgment in favor of MassDOT. The Supreme Judicial Court reversed, holding (1) while the intent of the parties should not be considered when an easement is taken by eminent domain, the ordinary rules of interpretation for easements otherwise apply; and (2) because the 1991 easement was more limited in scope than the 2018 easement, summary judgment for MassDOT must be reversed. View "Smiley First, LLC v. Dep't of Transportation" on Justia Law
Posted in:
Real Estate & Property Law, Transportation Law
Martin v. Commonwealth
The Supreme Judicial Court held that a defendant who has been serving the incarcerated portion of an illegal sentence imposed by the appellate division of the superior court has the same double jeopardy protections as a defendant who has been serving the incarcerated portion of an illegal sentence imposed by a single superior court judge.Defendant was convicted of indecent assault and battery. The appellate division revised Defendant's sentence by reducing the period of incarceration on two counts to from four to six years in prison. After it was discovered that Defendant's sentence was illegal the appellate division reversed the incarcerated portion of Defendant's sentence to concurrent terms of from five to six years. Defendant filed a petition under Mass. Gen. Laws ch. 211, 3 arguing that his resentence violated common-law principles of double jeopardy. The single justice denied the petition. The Supreme Judicial Court reversed, holding (1) when sufficient time has lapsed even an illegal sentence becomes final, and double jeopardy principles preclude the State from making upward adjustments to the sentence; and (2) Defendant was entitled to judgment on his petition. View "Martin v. Commonwealth" on Justia Law
Posted in:
Criminal Law
Commonwealth v. Gandia
In this action brought by the Commonwealth seeking relief from a trial court order requiring it to disclose information regarding a confidential informant the Supreme Judicial Court held that the motion judge in this case abused her discretion by failing to conduct the two-stage inquiry applicable to motions for disclosure of information subject to the Commonwealth's assertion of the informant privilege.After an informant notified police that Defendant was dealing crack cocaine Defendant was charged with a drug-trafficking offense and unlicensed operation of a motor vehicle. Defendant moved for disclosure of the name and address of the informant, as well as details relating to the informant's credibility. The motion judge allowed the motion. The Supreme Judicial Court reversed, holding that (1) the motion judge abused her discretion by failing to conduct the two-stage inquiry applicable to motions for disclosure of information subject to the Commonwealth's assertion of the informant privilege; and (2) the information sought was not sufficiently material or relevant to the defense to warrant the Commonwealth's assertion of the privilege. View "Commonwealth v. Gandia" on Justia Law
Posted in:
Criminal Law
Commonwealth v. Whitfield
The Supreme Judicial Court remanded this case to the county court for entry of a judgment reversing the order of the motion judge allowing Defendant's motion for discovery and requiring the Commonwealth to disclose information about a confidential informant, holding that the Commonwealth's invocation of the informant privilege was proper.
In obtaining a search warrant that led to the seizure of firearms from Defendant's apartment and Defendant's ensuing arrest on firearms and ammunition charges, the Commonwealth relied on information from the informant at issue. After he was charged, Defendant filed a motion seeking discovery of offers made to the informant and documents related to the informant's participation in other criminal investigations. The motion judge allowed the motion. The Supreme Judicial Court reversed, holding that the motion judge abused her discretion in granting the motion because the requested information would effectively disclose the informant's identity and Defendant failed to show that the informant was relevant and material to her defense. View "Commonwealth v. Whitfield" on Justia Law
Posted in:
Criminal Law
Kifor v. Commonwealth
The Supreme Judicial Court affirmed the judgment of the county court denying, without a hearing, Petitioner's petition for relief under Mass. Gen. Laws ch. 211, 3, holding that the single justice did not err or abuse his discretion by denying relief.Petitioner alleged in his petition that a number of State actors had been engaged in "deliberately child-predatory and subversionary public nuisance activities" in furtherance of a conspiracy against him. The single justice denied relief. The Supreme Judicial Court affirmed and took measures intended to prevent Petitioner from further abusing the system, holding that the single justice was not obligated to exercise the court's superintendent power to become involved in this matter. View "Kifor v. Commonwealth" on Justia Law
Posted in:
Civil Rights
Brown v. Federal National Mortgage Ass’n
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
Posted in:
Real Estate & Property Law
Herrmann v. Attorney General
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
Commonwealth v. Sullivan
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
Posted in:
Criminal Law