Justia Massachusetts Supreme Court Opinion Summaries

The defendant was convicted of first-degree murder on a felony-murder theory, with armed robbery as the predicate offense. The victim, who sold drugs from her apartment, was found stabbed to death. The defendant, a frequent customer who owed the victim money, was linked to the crime through text messages, surveillance footage, and DNA evidence. The victim's cell phones and a pill bottle with her name were missing, and a bloodstained jacket containing these items was found near the defendant's residence.The case was initially tried in the Superior Court, where the defendant was found guilty. The defendant appealed, arguing that the trial judge erred in admitting Y-STR DNA evidence, a compilation exhibit, and testimony from a substitute DNA analyst. He also contended that there was insufficient evidence to support the armed robbery charge.The Supreme Judicial Court of Massachusetts reviewed the case. The court held that the Y-STR DNA evidence was properly admitted, as it was presented with sufficient context for the jury to evaluate its significance. The court also found that the substitute analyst's testimony was not hearsay and that the compilation exhibit did not prejudice the defendant. Finally, the court concluded that there was sufficient evidence to support the armed robbery charge, as the jury could reasonably infer that the defendant took the victim's cell phones and pill bottle with the intent to steal.The Supreme Judicial Court affirmed the defendant's conviction and declined to grant relief under G. L. c. 278, § 33E, finding no reason to reduce the conviction or order a new trial. View "Commonwealth v. Souza" on Justia Law

The defendant was convicted of uttering after cashing a forged check drawn on an account of a person who did not know her. On January 19, 2019, the defendant cashed a personal check for $3,600 at a bank, presenting her driver's license. The check was drawn from an account belonging to an individual named Eileen, whose first name was misspelled on the check. The account holder later discovered unauthorized checks drawn on her account and contacted the police. The defendant was charged with larceny by check and uttering.The case was initially tried in the Malden Division of the District Court Department, where the defendant was found guilty of uttering but not guilty of larceny. The defendant's motion for a required finding of not guilty was denied. The Appeals Court affirmed the conviction, and the Supreme Judicial Court of Massachusetts granted further appellate review.The Supreme Judicial Court of Massachusetts reviewed the evidence to determine if it was sufficient to prove beyond a reasonable doubt that the defendant knew the check was forged. The court found that the evidence, including the account holder's unfamiliarity with the defendant, the misspelled signature, and the amount of the check, was insufficient to establish the defendant's knowledge of the forgery. The court emphasized that the evidence must be more than conjecture or inference piled upon inference. Consequently, the court reversed the judgment of the District Court, set aside the verdict, and ordered that judgment be entered for the defendant. View "Commonwealth v. Oliver" on Justia Law

The defendant was convicted of two counts of assault and battery by means of a dangerous weapon after attacking two victims with a hammer. The defendant admitted to hitting the victims but claimed self-defense. During the trial, the prosecution introduced a text message and social media posts to demonstrate the defendant's animosity toward the victims. The defendant sought to call an expert to dispute the authenticity of these posts, but the trial judge excluded the expert's testimony due to untimely disclosure.The case was first tried in the Superior Court, where the defendant was found guilty of more severe charges. On appeal, the Supreme Judicial Court reversed the convictions and ordered a new trial due to the improper exclusion of expert testimony. In the retrial, the defendant was convicted of the lesser included offense of assault and battery by means of a dangerous weapon. The Appeals Court later reversed these convictions, finding errors in the admission of the social media posts and the exclusion of the expert testimony. The Supreme Judicial Court then granted further appellate review.The Supreme Judicial Court of Massachusetts affirmed the trial court's decisions. The court held that the text message and social media posts were admissible as they were probative of the defendant's animus and intent, and their probative value was not outweighed by the risk of unfair prejudice. The court also found no abuse of discretion in excluding the expert testimony, as the late disclosure prejudiced the Commonwealth and the testimony was minimally material to the case's outcome. The judgments were affirmed. View "Commonwealth v. Hinds" on Justia Law

F.A. has been involuntarily committed to state mental health facilities since 1999 after being found not guilty of a sexual offense due to mental illness. In 2020, a District Court judge renewed F.A.'s commitment and imposed a restriction confining F.A. to the buildings and grounds of the facility. F.A. challenged the constitutionality of this restriction.Previously, the Worcester Division of the District Court Department had renewed F.A.'s commitment annually and imposed similar restrictions since 2013. In 2020, F.A. opposed the Commonwealth's motion for the restriction, but the judge granted it after an evidentiary hearing. The judge did not require the Commonwealth to prove beyond a reasonable doubt that the restriction was necessary. In 2021, a different judge imposed the same restriction without an evidentiary hearing. The Appellate Division of the District Court affirmed the 2020 restriction but vacated the 2021 restriction due to the lack of a hearing. F.A. appealed the 2020 decision, and the Supreme Judicial Court granted direct appellate review.The Supreme Judicial Court of Massachusetts reviewed the case and found that the 2020 order violated F.A.'s substantive and procedural due process rights. The court held that a restriction under G. L. c. 123, § 16 (e) must be narrowly tailored to a compelling government interest and be the least restrictive means available. The judge failed to make such findings and did not consider less restrictive alternatives. Additionally, the court found that the judge used an incorrect standard of proof and did not provide timely, specific findings to support the restriction. Consequently, the court vacated the 2020 order. View "In the Matter of F.A." on Justia Law

In two separate cases, mothers petitioned the Juvenile Court to involuntarily commit their children for inpatient care due to substance use disorders under Massachusetts General Laws c. 123, § 35. E.S. was committed for ninety days, and J.P. for thirty days, following hearings where family members and court clinicians testified about the juveniles' substance use and behaviors.In the case of E.S., the Bristol County Juvenile Court judge found clear and convincing evidence of a substance use disorder, citing E.S.'s history of alcohol and marijuana use, recent positive tests for fentanyl, and concerning behaviors such as stumbling and passing out. The judge also found a likelihood of serious harm due to the imminent risk posed by E.S.'s substance use and the lack of immediate outpatient care options. E.S.'s commitment was affirmed on appeal.For J.P., the Essex County Juvenile Court judge ordered commitment based on testimony about J.P.'s daily marijuana use, behavioral changes, and a single incident of driving under the influence. However, the court clinician did not find J.P. to be a danger to himself or others. On appeal, the Supreme Judicial Court found the evidence insufficient to support a likelihood of serious harm, noting the lack of clear evidence of imminent risk. J.P.'s commitment order was reversed.The Supreme Judicial Court of Massachusetts held that a finding of a substance use disorder under § 35 must be supported by clinical evidence to comply with substantive due process. The court affirmed E.S.'s commitment but reversed and vacated J.P.'s commitment, remanding the case for entry of an order consistent with its opinion. View "In the Matter of J.P." on Justia Law

In 2007, the defendant was convicted of first-degree murder on a felony-murder theory, with armed robbery as the predicate felony, and assault and battery by means of a dangerous weapon. The incident involved the defendant shoplifting, being confronted by store employees, and subsequently stabbing two employees, resulting in one death. The defendant's convictions were affirmed on direct appeal in 2011.In 2018, the defendant filed a motion for a new trial, claiming ineffective assistance of counsel for not employing a neuropsychologist to support a mental impairment defense. He also renewed a motion to reduce the verdict. A Superior Court judge held an evidentiary hearing in 2021, where expert testimony suggested the defendant's intent was impaired by panic during the incident. The motion judge denied the new trial motion but reduced the verdict to second-degree murder, citing a sense of injustice and referencing a recent legal standard requiring actual malice for murder convictions.The Supreme Judicial Court of Massachusetts reviewed the case. It affirmed the denial of the new trial motion, agreeing that the failure to present the mental impairment defense did not deprive the defendant of a substantial ground of defense. However, the court found that the motion judge abused his discretion in reducing the verdict. The reduction was improperly based on the sentence for first-degree murder and the judge's interpretation of a recent legal standard not applicable to the case. The court reversed the reduction of the verdict, reinstating the first-degree murder conviction. View "Commonwealth v. Rogers" on Justia Law

The plaintiffs, all State troopers, filed a lawsuit against the Commonwealth and the heads of the State Police and the State Board of Retirement. They claimed that the defendants' policy of denying the accrual of benefits, such as seniority, length-of-service credit, and vacation and sick time while on leave under the Paid Family and Medical Leave Act (PFMLA), violated the act. Additionally, they argued that the policy discriminated against female employees in violation of other state laws.A Superior Court judge dismissed the portion of the complaint alleging violations of the PFMLA. The judge concluded that the act does not guarantee the accrual of benefits during PFMLA leave. The plaintiffs then sought clarification on the interpretation of the act, and the case was reported to the Appeals Court. The Supreme Judicial Court of Massachusetts transferred the case to itself for review.The Supreme Judicial Court of Massachusetts held that the PFMLA does not require employers to guarantee the accrual of vacation and sick time during an employee's leave. The court interpreted the plain language of the statute, particularly sections 2(e) and 2(f), and concluded that while employees must be restored to their previous position with the same status and benefits upon returning from leave, the act does not mandate the continued accrual of benefits during the leave period. The court affirmed the lower court's dismissal of the PFMLA claims and remanded the case for further proceedings consistent with its opinion. View "Bodge v. Commonwealth" on Justia Law

The case involves Susan Hartnett, a public employee who worked for the Commonwealth from 1978 to 1990 and then rejoined public service in 2002, working for the city of Boston. Upon her return, her salary more than doubled compared to her 1990 salary. Hartnett continued working until 2006 and deferred her retirement until 2016. Initially, her pension was calculated without applying the anti-spiking provision of the public employee pension statute, but after an audit, the Boston Retirement System (BRS) applied the provision, reducing her pension.Hartnett challenged the application of the anti-spiking provision. The Division of Administrative Law Appeals (DALA) and the Contributory Retirement Appeal Board (CRAB) affirmed BRS's decision. Hartnett then sought judicial review in the Superior Court, which ruled in her favor, concluding that the anti-spiking provision did not apply because the years 1990 and 2002 were not "two consecutive years" under the statute. The agencies appealed, and the case was transferred to the Supreme Judicial Court of Massachusetts.The Supreme Judicial Court of Massachusetts held that the phrase "two consecutive years" in the anti-spiking provision refers to two back-to-back years without interruption. The court found that the plain meaning of "consecutive" means following one after another without interruption, and this interpretation is consistent with the statutory scheme. The court rejected the agencies' argument that "two consecutive years" should mean two creditable years of service without another intervening year of service. Consequently, the court affirmed the Superior Court's judgment in favor of Hartnett, ruling that the years 1990 and 2002 are not "two consecutive years" under the anti-spiking provision. View "Hartnett v. Contributory Retirement Appeal Board" on Justia Law

The case involves a proposed electric substation in East Boston by NSTAR Electric Company, doing business as Eversource Energy. The Energy Facilities Siting Board (the board) granted a certificate of environmental impact and public interest to Eversource for the substation. The petitioners, Conservation Law Foundation and GreenRoots, Inc., challenged this decision, arguing that Eversource failed to show "undue delay" by two city agencies, and that the board did not properly consider environmental justice principles, among other issues.Previously, Eversource's petition to build the substation was approved by the board in 2017, with a project change approved in 2018. The petitioners intervened in the proceedings, and the board issued a decision in November 2022, granting the certificate. The petitioners then filed for judicial review in the Supreme Judicial Court for the county of Suffolk.The Supreme Judicial Court of Massachusetts reviewed the case and upheld the board's decision. The court found that the board's determination of "undue delay" by the city agencies was supported by substantial evidence. The court also concluded that the board properly considered environmental justice principles, including the equitable distribution of energy benefits and burdens. Additionally, the court found that the board's decision to issue the equivalent of a G. L. c. 91 tidelands license was lawful and supported by substantial evidence. The court affirmed the board's findings on the need for the substation, its compatibility with environmental protection, public health, and safety, and its alignment with the public interest. The decision of the board was affirmed. View "Conservation Law Foundation v. Energy Facilities Siting Board" on Justia Law

The case involves the defendant, who was indicted for unlawful possession of a firearm and related offenses after Boston police officers monitored his Snapchat account and observed him brandishing firearms in several videos. The police used an undercover Snapchat account to send a friend request to the defendant, who accepted it, allowing the officers to view his posts. The defendant was arrested twice, once in January 2018 and again in May 2018, each time after posting videos showing him with firearms.In the Superior Court, the defendant filed multiple discovery motions seeking information about the Boston Police Department's (BPD) use of undercover social media monitoring, arguing that it was relevant to an equal protection claim of discriminatory enforcement. The court granted these motions, ordering the Commonwealth to disclose various pieces of information, including the usernames and profile images used by undercover officers. The Commonwealth refused to comply, citing concerns about compromising ongoing investigations and endangering informants.The Supreme Judicial Court of Massachusetts reviewed the case. The court held that the Commonwealth did not properly assert a privilege to withhold the requested information, as it failed to demonstrate a legitimate need to protect ongoing investigations or the safety of informants. The court also affirmed the lower court's application of the equal protection standard from Commonwealth v. Long, which applies to claims of discriminatory law enforcement practices beyond traffic stops.The court concluded that the Superior Court judge did not abuse his discretion in dismissing the indictments with prejudice as a sanction for the Commonwealth's deliberate non-compliance with the discovery order. The dismissal was deemed appropriate because the Commonwealth's refusal to provide the requested discovery denied the defendant the opportunity to develop his equal protection claim, thus preventing a fair trial. View "Commonwealth v. Dilworth" on Justia Law