Justia Massachusetts Supreme Court Opinion Summaries

In this case, the defendant was convicted of first-degree murder. The incident occurred on February 6, 2006, when the victim was shot multiple times in an apartment building. Several witnesses, including Corrin Cripps, Jeanette Martinez, and Michael Gomes, identified the defendant as the shooter. Cripps and Martinez were using cocaine at the time of the incident, and Gomes initially failed to identify the defendant in a photographic array. The defendant was later found in Puerto Rico, where he provided an alias to the police.The defendant's conviction was previously affirmed by the Supreme Judicial Court of Massachusetts, along with the denial of his first motion for a new trial. In November 2022, the defendant filed a second motion for a new trial, arguing that newly discovered evidence regarding the unreliability of eyewitness identifications entitled him to a new trial. This motion was denied by a Superior Court judge, and the defendant sought leave to appeal from a single justice of the Supreme Judicial Court, which was granted on the issue of the new eyewitness identification science.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the denial of the second motion for a new trial. The court agreed that the new research on eyewitness identification was indeed newly discovered evidence. However, it concluded that this new evidence would not have been a real factor in the jury's deliberations. The court noted that the new research primarily addressed the unreliability of stranger identifications, which was only relevant to one of the three eyewitnesses. Additionally, the jury had already been made aware of the potential issues with the eyewitness identifications through cross-examination. The court also pointed out that there was other evidence of the defendant's guilt, including his intent and consciousness of guilt demonstrated by his actions after the shooting. Therefore, the court held that the absence of the new evidence did not cast real doubt on the justice of the conviction. View "Commonwealth v. Mercado" on Justia Law

In August 2021, five defendants responded to online advertisements offering sexual services for a fee. The advertisements, posted by undercover police officers, depicted an adult woman and listed various sexual services. Each defendant contacted the purported sex worker, selected services, agreed to the set price, and went to the specified location. Upon arrival, they were arrested by police officers.A Plymouth County grand jury indicted each defendant for trafficking of persons for sexual servitude under G. L. c. 265, § 50, and engaging in sexual conduct for a fee under G. L. c. 272, § 53A. The defendants moved to dismiss the sex trafficking charges, arguing that the facts did not support probable cause. A Superior Court judge allowed the motions, reasoning that the defendants did not attempt to traffic "another person" since the sex worker was an undercover officer. The Commonwealth appealed, and the Appeals Court affirmed the dismissal, concluding that the evidence did not constitute trafficking of a person for sexual servitude. The Commonwealth then sought further appellate review.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the dismissal of the sex trafficking indictments. The court held that the defendants' conduct of responding to advertisements, agreeing to terms, and going to the location did not constitute "trafficking of persons for sexual servitude" under G. L. c. 265, § 50. The court concluded that the statute did not apply to purchasers who respond to offers from independent sex workers and accept the terms set by the sex worker. The court emphasized that the statute targets those involved in the operation of sex trafficking schemes, not the subset of purchasers targeted by the sex for a fee statute. The case was remanded for further proceedings on the remaining indictments. View "Commonwealth v. Garafalo" on Justia Law

Two detectives from the Lowell police department, while investigating a home invasion in Lowell, Massachusetts, crossed into Nashua, New Hampshire, to speak with the defendant. During the conversation, one detective suspected the defendant was deleting data from his cell phone and seized it without a warrant. The detectives then brought the phone back to Massachusetts and obtained a warrant to search it.In the Superior Court, the defendant moved to suppress the evidence obtained from the cell phone, arguing that the seizure was unlawful. The motion judge allowed the motion, finding that the Lowell detectives had no authority to seize the phone in New Hampshire. The Commonwealth sought an interlocutory appeal, which was allowed by a single justice of the Supreme Judicial Court for the county of Suffolk. The case was then transferred to the Supreme Judicial Court on its own initiative.The Supreme Judicial Court of Massachusetts reviewed the case and concluded that the Lowell detective did not have extraterritorial authority to seize the cell phone in New Hampshire. The court found that no statutory or common law authority permitted the warrantless seizure in these circumstances. The court also rejected the Commonwealth's argument that the evidence would have been inevitably discovered, as this theory was not sufficiently supported by the record. The court held that suppression of the evidence was the appropriate remedy to deter police misconduct and preserve judicial integrity. The order allowing the motion to suppress was affirmed. View "Commonwealth v. McCarthy" on Justia Law

A child was born on May 30, 2017, to unmarried parents. The mother, A.D., believed Q.T. was the father, and he signed a Voluntary Acknowledgment of Parentage (VAP) on June 1, 2017. However, a DNA test on July 6, 2017, revealed Q.T. was not the biological father. Despite this, the VAP was not rescinded within the statutory period, and Q.T. ceased contact with the child. Years later, the mother identified K.S. as the potential biological father through a DNA testing platform and filed multiple complaints to establish K.S. as the legal father.The Middlesex Division of the Probate and Family Court initially dismissed the mother’s complaints due to procedural issues and the existing VAP. However, after consolidating the sixth and seventh complaints, the court ordered genetic marker testing, which confirmed K.S. as the biological father. The court then rescinded the VAP, declared K.S. the legal father, and ordered changes to the child’s birth certificate.The Supreme Judicial Court of Massachusetts reviewed the case. The court held that the Probate and Family Court judge lacked the authority to override the statutory deadlines for rescinding a VAP. The statute of repose under G. L. c. 209C, § 11(a), establishes strict time limits for challenging a VAP, which had long expired in this case. The court emphasized the legislative intent to provide finality in parentage determinations for the stability and security of the child. Consequently, the Supreme Judicial Court vacated the lower court’s judgments and remanded the case for proceedings consistent with its opinion. View "A.D. v. K.S." on Justia Law

A child was removed from her mother's care by the Department of Children and Families (DCF) shortly after birth due to neglect. The child spent most of her life in foster care. In February 2019, a Juvenile Court judge awarded custody to the child's father, a New Hampshire resident, despite the absence of an Interstate Compact on the Placement of Children (ICPC) report. The child went missing after moving to New Hampshire with her father and is presumed dead. The father was later convicted of her murder.The journalist sought access to audio recordings of the February 2019 hearings where custody was awarded to the father. The Juvenile Court judge denied the request, applying the Uniform Rules on Impoundment Procedure (URIP). The journalist filed a motion for reconsideration, which was also denied. The case was transferred to the Supreme Judicial Court.The Supreme Judicial Court of Massachusetts reviewed the case and determined that the good cause standard under Rule 7(b) of the URIP was the appropriate test for evaluating the journalist's request. The court found that the privacy interests of the parties involved were minimal, given the extensive public disclosure of the case details. The court also recognized the significant public interest in understanding the child welfare system and the circumstances leading to the child's death.The court concluded that the journalist demonstrated good cause for the release of the February 2019 hearing recordings for use in a documentary, subject to specific redactions and conditions. The order denying the motion for access was vacated, and the case was remanded to the Juvenile Court for the release of the recordings with the specified limitations. View "Care and Protection of Adele" on Justia Law

The defendant was convicted of deliberately premeditated murder in the first degree for the shooting death of Jesus Flores at the entrance of a Springfield nightclub. The primary issue at trial was the identification of the defendant as the shooter, which the Commonwealth supported with surveillance video footage. The defendant argued that the poor quality of the footage made it impossible to prove identification beyond a reasonable doubt.A Superior Court jury found the defendant guilty of murder in the first degree. However, the trial judge later reduced the verdict to murder in the second degree, citing insufficient evidence of deliberate premeditation and lethal intent. The defendant appealed, arguing that the evidence was insufficient to support the conviction, the compilation video was improperly admitted, and a police officer's testimony about a hearsay statement from the victim was wrongly allowed. The Commonwealth also appealed the reduction of the verdict.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the conviction of murder in the first degree. The court found that the evidence was sufficient for a rational jury to identify the defendant as the shooter and that the compilation video was properly admitted. The court also ruled that the victim's statement was admissible to rebut the defendant's challenge to the adequacy of the police investigation. Finally, the court reversed the trial judge's reduction of the verdict, reinstating the jury's original verdict of murder in the first degree, and remanded the case for resentencing. The court held that the weight of the evidence supported the jury's finding of deliberate premeditation and intent to kill. View "Commonwealth v. Gomez" on Justia Law

The defendant, Clough, Harbour & Associates LLP (CHA), agreed to design a new athletic field for the plaintiff, Trustees of Boston University (university). The contract included an express indemnification provision, which required CHA to indemnify the university for any expenses resulting from CHA's negligent design. A defect in CHA's design caused the university to incur expenses to fix the field. The university demanded indemnification from CHA, which CHA refused. More than six years after the field opened, the university sued CHA for breach of the indemnification provision.The Superior Court judge granted summary judgment in favor of CHA, relying on the tort statute of repose, which bars tort actions for damages arising from design defects in real property improvements six years after the improvement's opening. The judge concluded that the university's claim was barred by this statute. The university appealed the decision.The Supreme Judicial Court of Massachusetts reviewed the case. The court held that the tort statute of repose does not apply to the university's contract claim for indemnification. The court emphasized that the claim was based on an express contractual provision, not a tort duty imposed by law. The court distinguished between claims for breach of an implied warranty, which are barred by the statute of repose, and claims for breach of an express warranty or indemnification provision, which are not. The court reversed the Superior Court's decision and remanded the case for further proceedings. View "Trustees of Boston University v. Clough, Harbour & Associates LLP" on Justia Law

Jeff Stacy, a lineman for Unitil Corporation, continued working during the COVID-19 pandemic as his job was classified as an essential service. Despite the Governor's orders to shut down nonessential businesses, Stacy worked closely with colleagues, which led to his exposure to the virus. In February 2021, after working overtime during snowstorms, Stacy contracted COVID-19 from a coworker, resulting in severe illness and total disability. He applied for workers' compensation benefits, which were initially denied by his employer's insurer, Travelers Indemnity Company of Connecticut.An administrative judge from the Department of Industrial Accidents held an evidentiary hearing and ruled in favor of Stacy, finding that the risk of contracting COVID-19 was inherent in his employment during the pandemic. The judge noted that Stacy's job required close physical proximity to coworkers, increasing his risk of infection. The Industrial Accident Reviewing Board affirmed the judge's decision, adopting the factual findings and concluding that the decision was supported by adequate evidence and reasoned decision-making.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the board's decision. The court held that the board's determination that the risk of contracting COVID-19 was inherent in Stacy's employment was not arbitrary or capricious. The court emphasized that Stacy's role as an essential worker, who continued to work closely with others during a time when most businesses were closed and social distancing was mandated, justified the finding that his employment posed a unique risk of infection. Thus, Stacy's claim for workers' compensation benefits was upheld. View "Stacy's Case" on Justia Law

A juvenile was found delinquent on firearm charges and guilty on a youthful offender indictment for one of the offenses. At the trial, the juvenile was nineteen years old, and the Commonwealth called his mother to testify about events that occurred when he was seventeen. The juvenile argued that the parent-child witness disqualification statute, which prohibits testimony by a parent against their minor child, should have precluded his mother's testimony even though he was no longer a minor at the time of trial. He also claimed that the trial judge made several errors in admitting other evidence and that his sentence was unlawful and unconstitutional.The juvenile was charged in a delinquency complaint with possession of a firearm without a firearm identification card, unlawful possession of a large capacity feeding device, and improper storage of a firearm. He was subsequently indicted as a youthful offender for the large capacity feeding device charge. The juvenile filed a motion to prevent the Commonwealth from calling his mother as a witness, invoking the parent-child witness disqualification statute. The motion judge denied the motion, reasoning that the statute applied only to testimony against a minor child, and the juvenile was no longer a minor.The Supreme Judicial Court of Massachusetts reviewed the case and agreed with the trial judge's interpretation that the statutory prohibition of testimony by a parent against their minor child does not apply once the child has reached the age of eighteen. The court found no prejudicial error in the admission of other evidence, although it concluded that the judge should not have admitted a detective's testimony that a firearm depicted in still images was "identical" to the firearm admitted in evidence, nor two hearsay statements. Regarding the juvenile's sentence, the court agreed that the judge erred in not issuing written findings explaining the sentence but concluded that this error did not prejudice the juvenile. The court affirmed the juvenile's delinquency and youthful offender adjudications and declined to vacate his sentence. View "Commonwealth v. Rajiv R." on Justia Law

The defendant was found guilty of first-degree murder, improper disposal of a body, and willfully misleading a police officer. The case involves the killing of a long-time friend, whose body was discovered by a passerby in a wooded area. The victim was identified through fingerprint records, and his cause of death was determined to be acute cyanide toxicity. The investigation revealed that the defendant and the victim had met on the day of the victim's death, and the defendant had given inconsistent and false statements to the police about their meeting.In the Superior Court, the defendant's pretrial motions to suppress evidence obtained from searches and his statements to the police were denied. The trial proceeded with the Commonwealth presenting evidence of the defendant's financial troubles and his purchase of cyanide. The defense argued that the defendant's confessions were not voluntary due to his medical and emotional state following a suicide attempt. The jury found the defendant guilty on all charges, and he was sentenced to life in prison for the murder conviction, with concurrent sentences for the other charges.The Supreme Judicial Court of Massachusetts reviewed the case. The defendant argued that the evidence obtained from the searches should have been suppressed due to lack of probable cause and that his statements to the police were involuntary. The court found no error in the denial of the motions to suppress, concluding that the affidavits provided sufficient probable cause and that the defendant's waivers of his Miranda rights and his statements were voluntary. The court affirmed the defendant's convictions and declined to order a new trial or reduce the conviction. View "Commonwealth v. Camuti" on Justia Law