Justia Massachusetts Supreme Court Opinion Summaries

The defendant killed his former high school girlfriend by strangling and cutting her throat after their relationship ended. In the months leading up to the crime, he exhibited signs of emotional distress and had several altercations with the victim and others. On the day of the killing, he took calculated steps to conceal his involvement, including moving the victim’s body, cleaning evidence, and misleading police about their interactions. During trial, the defendant admitted to the killing but argued he was not criminally responsible due to mental illness, presenting expert testimony regarding his psychological state.In the Superior Court, the defendant was convicted of first-degree murder on theories of deliberate premeditation and extreme atrocity or cruelty, along with assault and battery charges. He was sentenced to life without parole. After his conviction, he filed a motion to suppress evidence obtained from searches of his home and vehicle, arguing lack of probable cause, which the court denied. Later, he moved for a new trial, citing newly discovered evidence of developing schizophrenia after the crime. After an evidentiary hearing, a Superior Court judge denied the motion, finding the new evidence did not cast real doubt on the justice of the conviction.The Supreme Judicial Court of Massachusetts reviewed the consolidated appeals from the convictions and denial of the new trial motion. The court held that the lower court did not err or abuse its discretion in denying the new trial or in its evidentiary rulings. It also found the denial of the suppression motion proper, concluding the warrants were supported by probable cause. The court affirmed all convictions and the denial of the new trial motion. However, it held that the sentence of life without parole was unconstitutional for defendants under twenty-one and remanded for resentencing to life with parole eligibility after fifteen years. View "Commonwealth v. Fujita" on Justia Law

After experiencing medical complications following a delayed appendectomy, a nineteen-year-old patient brought a medical malpractice action against a hospital, its corporate affiliate, and several health care providers. The patient had gone to the hospital's emergency department with abdominal pain and other symptoms and was initially diagnosed with a urinary tract infection and discharged. She returned the next day with worsening pain, was diagnosed with acute appendicitis, and underwent surgery after a twelve-hour delay. The appendicitis had perforated, resulting in additional surgeries and complications, including abdominal abscess and pleural effusion, and a prolonged hospital stay.The patient filed her complaint in the Superior Court, alleging negligence and adverse consequences from delayed diagnosis and treatment. She moved to impound her medical records, arguing for their confidentiality, but the judge denied her motion, citing failure to show good cause and allowing her to refile with more specificity, which she declined. She also sought a protective order, which was similarly denied. For the medical malpractice tribunal process, the plaintiff submitted an expert opinion letter without her medical records. The tribunal found the offer of proof insufficient to raise a legitimate question of liability for judicial inquiry. The plaintiff failed to post the required bond within thirty days of the tribunal’s finding, resulting in dismissal of her claims. The Appeals Court affirmed both the dismissal and the denial of impoundment.On further appellate review, the Supreme Judicial Court of Massachusetts held that the judge did not abuse discretion in denying impoundment of the medical records, as the plaintiff failed to provide particularized information or establish good cause. The court also held that the medical malpractice tribunal did not err in finding the offer of proof insufficient, as it lacked specific information regarding each defendant’s conduct. The Supreme Judicial Court affirmed both the denial of the impoundment motion and the judgment of dismissal. View "DosSantos v. Beth Israel Deaconess Hospital-Milton, Inc." on Justia Law

On the evening of July 4, 2018, a man was killed while sitting with his wife on a Boston sidewalk watching fireworks. The defendant drove his girlfriend’s car with Travis Phillips in the passenger seat. As they passed the victim, Phillips used a laser-guided firearm to shoot and kill him. Security footage captured both the events leading up to and following the shooting. Evidence linked the defendant to the car, including fingerprint and DNA analysis, and to the distinctive clothing he wore that night. Police also discovered and seized a cell phone from the defendant’s bedroom, which contained photographs and metadata relevant to the timeline and location of the shooting.The defendant was indicted on charges of murder in the first degree and unlawful possession of a firearm in the Massachusetts Superior Court. He filed two motions to suppress evidence related to the cell phone, both of which were denied. His theory at trial was that the Commonwealth had failed to prove he was the driver or that he shared Phillips's lethal intent. A jury convicted him on both charges. He appealed directly to the Supreme Judicial Court of Massachusetts, raising arguments about sufficiency of evidence regarding intent, prosecutorial misconduct in statements and arguments, and the legality of the cell phone search and seizure.The Supreme Judicial Court of Massachusetts affirmed the murder conviction, holding that the evidence was sufficient to permit the jury to find shared lethal intent, that the prosecutor’s statements did not exceed permissible bounds, and that the seizure and search of the cell phone were supported by probable cause and not unreasonably delayed or overly broad. However, the court vacated the firearm conviction and remanded for further proceedings because the jury had not been instructed that the Commonwealth bore the burden of proving the absence of a valid firearms license. View "Commonwealth v. Carleton" on Justia Law

The defendant and his girlfriend entered the home of an elderly couple, Thomas Harty and Joanna Fisher, where they stabbed and suffocated the victims, stole their valuables, and fled in the victims’ car. Harty died immediately. Fisher, a nonambulatory, seventy-seven-year-old woman who used a wheelchair, survived initially but later died from complications due to multiple stab wounds. The defendant was convicted of murder in the first degree for both victims and, as to Fisher, also of attempted murder.Previously, the Supreme Judicial Court of Massachusetts reviewed and affirmed the convictions, but noted that the jury instruction for attempted murder incorrectly included the failure to complete murder as an element. The court allowed the defendant to raise the issue of legally inconsistent verdicts in a postconviction motion. The Superior Court, after considering whether the acts supporting the attempted murder and murder convictions were sufficiently separate and whether the defendant had notice of alternate theories, found both questions answered in the affirmative and denied the defendant’s motion to vacate the convictions.On further appeal, the Supreme Judicial Court of Massachusetts held that the verdicts were not legally inconsistent. The court concluded that the jury could reasonably have found that the defendant’s act of attempting to smother Fisher with pillows was separate from the subsequent fatal stabbing, and each act could support distinct convictions. The court also found that the defendant received adequate notice of the theories underlying each charge. Therefore, the court affirmed the order denying the defendant’s motion to vacate the convictions, holding that no substantial likelihood of a miscarriage of justice resulted from the erroneous jury instruction. View "Commonwealth v. Hart" on Justia Law

Kelsey Fitzsimmons, a North Andover police officer, was indicted in Essex County on one count of assault by means of a dangerous weapon. The Commonwealth alleged that during the service of an abuse prevention order, Fitzsimmons deceived officers regarding firearms in her home, drew a firearm, pointed it at an officer, and pulled the trigger, though the gun did not discharge. She then allegedly attempted to chamber a round before being shot by an officer. The Commonwealth presented further evidence of Fitzsimmons’s prior alcohol-related violence, mental health struggles, and a 2019 misdemeanor conviction for intoxicated and disruptive behavior. Fitzsimmons relied on medical and psychological evidence suggesting she was suitable for outpatient care and posed no credible risk of harm.Initially, the District Court ordered Fitzsimmons held on dangerousness grounds. A Superior Court judge subsequently found her dangerous but released her subject to strict conditions, including house arrest, GPS monitoring, and alcohol abstinence monitored by SCRAM testing. When Fitzsimmons claimed she could not physically comply with SCRAM testing due to injuries, the judge vacated the release order and detained her pretrial. Fitzsimmons moved for reconsideration, proposing urine testing as an alternative, but the judge denied the motion, finding that urine testing would interfere with house arrest requirements.Fitzsimmons then petitioned a single justice of the Supreme Judicial Court of Massachusetts for extraordinary relief under G. L. c. 211, § 3, arguing the judge erred in refusing less restrictive alternatives and in her conduct. The single justice denied the petition, concluding there was no error or abuse of discretion. On appeal, the Supreme Judicial Court affirmed, holding that neither the hearing judge nor the single justice abused their discretion in ordering detention when Fitzsimmons could not comply with the least restrictive conditions necessary for community safety. The Court also found no requirement for de novo review and rejected Fitzsimmons’s arguments under the Americans with Disabilities Act and other statutes. Judgment was affirmed. View "Fitzsimmons v. Commonwealth" on Justia Law

The case concerns a defendant who pleaded guilty in 2012 to multiple sex offenses involving his minor children. He was sentenced to ten years in state prison followed by ten years of probation, with mandatory global positioning system (GPS) monitoring as a condition of probation under Massachusetts law. The statute required GPS monitoring for the entirety of his probation, but at the time of sentencing, no specific exclusion zones were established. After serving his prison sentence and two years of probation with GPS monitoring, the defendant sought relief from the GPS monitoring condition, arguing that it was unreasonable and unconstitutional, particularly due to its ten-year duration.After the Supreme Judicial Court’s decision in Commonwealth v. Feliz, which required individualized judicial findings regarding the reasonableness of GPS monitoring as a probation condition, the defendant filed a motion in the Superior Court for such an individualized assessment. The Superior Court judge denied the motion, finding that the Commonwealth had shown continued GPS monitoring was reasonable, based in part on the defendant’s classification as a level three sex offender and the victims’ statements about ongoing harm. However, the judge did not make findings regarding the reasonableness of the specific ten-year duration of GPS monitoring.The Supreme Judicial Court of Massachusetts reviewed the case on direct appellate review. The Court held that a judge must consider the duration of GPS monitoring in evaluating its reasonableness under the Massachusetts Declaration of Rights. The holding clarified that a judge may only impose GPS monitoring for a duration found to be reasonable, even if that period is less than the statutory term of probation. Because the Superior Court judge did not evaluate the ten-year duration, the Supreme Judicial Court vacated the order denying the defendant’s motion and remanded for further proceedings consistent with its opinion. View "Commonwealth v. Arnold" on Justia Law

A commercial landlord leased property in downtown Boston to a restaurant operator. As part of their lease agreement, the landlord sold the restaurant a liquor license for one dollar, with the understanding that the license would be transferred back to the landlord for one dollar at the end of the lease. The lease included a provision prohibiting the restaurant from pledging the liquor license as collateral for any loan without the landlord’s written consent. Despite this, before the lease ended, the restaurant pledged the license to its principal as collateral for a loan. When the landlord discovered this, it terminated the lease and demanded the return of the license.The landlord and its related entities filed suit in the Massachusetts Superior Court, alleging breach of contract, unfair or deceptive business practices under General Laws c. 93A, and conversion. The Superior Court granted partial summary judgment for the landlord on the contract claims, finding the anti-pledge provision enforceable and the pledge a default. After a bench trial, the court found for the landlord on the c. 93A and conversion claims, awarding treble damages, attorney's fees, and costs. The defendants appealed these decisions.The Supreme Judicial Court of Massachusetts reviewed the case after transferring it from the Appeals Court. The Supreme Judicial Court held that the anti-pledge provision did not violate public policy or state law and was therefore enforceable. The court affirmed that the principal’s conduct in falsely affirming to regulatory authorities that the pledge did not violate any agreements constituted willful and knowing unfair or deceptive conduct under c. 93A. However, while the court affirmed the breach of contract claim, it reversed the conversion judgment, finding that the landlord did not have actual or immediate right to possession of the license at the relevant time. The award of attorney's fees and costs was affirmed. View "Nicosia v. Burns, LLC" on Justia Law

The case arose from a criminal prosecution in which the defendant was charged with violating an abuse prevention order issued under Massachusetts General Laws chapter 209A. The order directed the defendant to "stay away" from the victim's residence, which was a multi-unit building, but did not set a specific distance for compliance. On the day in question, the defendant was observed by police walking on a street parallel and behind the victim’s residence, eventually reaching a point approximately 200 feet away from the victim’s home but on the opposite side of the block. He was arrested at that location. There was no evidence the defendant entered the victim’s property or that the victim was at home at the time.The Cambridge Division of the District Court Department conducted a jury trial, at which the defendant was convicted of violating the abuse prevention order. The defendant’s motions for a required finding of not guilty were denied at multiple stages. On appeal, the Appeals Court affirmed the conviction, concluding that the evidence was sufficient for a rational jury to find a violation. The defendant sought, and was granted, further appellate review by the Supreme Judicial Court.The Supreme Judicial Court of Massachusetts reviewed the evidence under the standard of whether any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt. The Court held that, even viewing the evidence in the light most favorable to the Commonwealth, the evidence was insufficient to prove that the defendant had positioned himself so proximate to the victim’s property that he would have been able to abuse or contact the victim if she were present. Accordingly, the Supreme Judicial Court reversed the conviction, set aside the verdict, and ordered that judgment enter for the defendant. View "Commonwealth v. Carino" on Justia Law

The defendant was convicted, along with a codefendant, of murder in the first degree by extreme atrocity or cruelty after a joint jury trial in 1984. The killing occurred during a fight, and both men received mandatory sentences of life without parole. More than thirty years later, the defendant moved for a new trial, arguing that his trial counsel ignored his repeated requests to seek a plea bargain for a lesser charge, specifically murder in the second degree, which carries the possibility of parole. The defendant claimed he did not learn until 2016 that his attorney had not pursued plea negotiations and that the prosecutor might have been open to a plea if both defendants agreed.After the original convictions were affirmed by the Supreme Judicial Court under plenary review, the codefendant separately moved for a new trial, asserting ineffective assistance in plea negotiations. The Superior Court judge held evidentiary hearings on both the codefendant’s and the defendant’s motions. The judge found that neither attorney had secured or pursued a pretrial plea to murder in the second degree, and that the prosecutor would only have considered such a plea if both defendants agreed. Since this circumstance never arose before trial, the judge denied both motions, finding the arguments were speculative.On appeal, the Supreme Judicial Court of Massachusetts considered whether ineffective assistance may be found when counsel fails to pursue a reasonable plea negotiation at the defendant’s request. The court held that such a claim requires a showing that counsel’s failure was unreasonable and resulted in prejudice—specifically, a reasonable probability that the prosecutor and judge would have accepted the plea, and that the defendant suffered a more severe outcome by going to trial. The court affirmed the denial of the defendant’s motion for a new trial, concluding that there was no reasonable probability a stand-alone plea would have been accepted by the prosecutor. View "Commonwealth v. Mosso" on Justia Law

The case concerns an individual who was tried on six charges involving sexual abuse of minors. At trial, the jury acquitted him on five counts relating to two minors but convicted him on one count involving a third minor. After the trial, he filed a timely notice of appeal. Subsequently, the Executive Office of the Trial Court issued a notice under the Massachusetts automatic sealing statute, informing him that records relating to the acquitted counts would be sealed unless he requested otherwise. The notice also stated that he would lose access to those records once sealed. The individual did not respond, and some records were sealed.After this, appellate counsel was appointed to represent the individual on appeal. Counsel attempted to obtain the trial records, including those pertaining to the acquitted counts, but discovered that certain documents had been sealed. Counsel then moved for access to these sealed documents, arguing that not having access would hinder effective appellate representation. The motion judge allowed only limited access—counsel could view the documents at the clerk’s office under supervision and take notes, but could not make copies. The individual submitted an affidavit authorizing counsel’s access, but the motion judge maintained the restrictions. Seeking broader access, the individual petitioned a single justice of the Supreme Judicial Court under G. L. c. 211, § 3. The single justice reserved and reported the matter to the full court.The Supreme Judicial Court of Massachusetts held that the automatic sealing statute does not preclude a defendant or the defendant’s appellate counsel from accessing the defendant’s own sealed criminal records. The court concluded that the statute’s text, legislative history, and related statutory framework support the view that sealing is aimed at precluding public access—not preventing the defendant and counsel from reviewing the records necessary for appeal. The court vacated the lower court’s order restricting access and remanded for entry of an order providing access to the sealed records. View "Gravito v. Commonwealth" on Justia Law