Justia Massachusetts Supreme Court Opinion Summaries

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The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on a theory of extreme atrocity or cruelty, holding that there was no error that would require reversal of Defendant's convictions.Defendant's first trial ended in a mistrial because the jury were unable to reach a verdict. After a retrial, Defendant was convicted of murder. On appeal, Defendant challenged the trial court's denial of his motion to suppress his cell site location information (CSLI) and any "fruits" derived from it. The Supreme Judicial Court affirmed, holding (1) law enforcement infringed upon Defendant's reasonable expectation of privacy in his CSLI without a warrant, but the error was harmless; (2) trial counsel was not ineffective for failing to instruction to certain portions of the jury instructions; and (3) Defendant was not entitled to relief on his remaining claims of error. View "Commonwealth v. Gumkowski" on Justia Law

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The Supreme Judicial Court affirmed the decision of the Appeals Court affirming the denial of a single justice of the Appeals Court denying Defendant's motion to stay execution of his sentence, holding that the Appeals Court did not err in denying Defendant's motion for a stay of execution of sentence.Defendant was convicted of murder in the second degree and other offenses. Defendant later filed a motion for a new trial. The motion was denied, and Defendant's appeal was pending. Defendant also filed a motion to stay execution of sentence. A single justice denied the motion, and the court of appeals affirmed. The Supreme Judicial Court affirmed, holding that there was no error or abuse of discretion in the denial of a stay pending appeal from the denial of Defendant's motion for a new trial. View "Commonwealth v. Harris" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court dismissed in part and affirmed in part the judgment of the single justice of the court denying Petitioners' petition filed under Mass. Gen. Laws ch. 211, 3 seeking a stay of execution of their sentences pending decisions on their motions for a new trial, holding that the single justice did not err.Joseph Pope and Floyd Hamilton (together, Petitioners) were each convicted of murder in the first degree and armed robbery. Both petitioners filed second motions for a new trial and a motion to stay execution of sentence pending decision thereon. After the superior court denied the motions Petitioners' motions to stay, Petitioners brought this Mass. Gen. Laws ch. 211, 3 petition. The single justice denied relief without a hearing. The Supreme Judicial Court held (1) Pope's appeal from the single justice's judgment was moot; and (2) the single justice did not err by denying a stay of Hamilton's sentence pending decision on his motion for a new trial. View "Pope v. Commonwealth" on Justia Law

Posted in: Criminal Law
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The Court of Appeals answered a question certified to it by the Federal District Court for the District of Massachusetts by holding that the thirty-day time limitation established in Mains v. Commonwealth, 433 Mass. 30 (2000), for filing a gatekeeper petition under Mass. Gen. Laws ch. 278, 33E does not apply to denials that occurred before December 13, 2000.Petitioner was convicted of murder in the first degree and armed assault with intent to murder. Petitioner later filed a federal habeas petition. Respondent filed a motion to dismiss, arguing that the petition was untimely under the deadline set forth in the Antiterrorism and Effective Death Penalty Act, 28 U.S.C. 2244(d)(1). At issue was whether the time limitation established in Mains for filing a gatekeeper petition applies to denials that occurred prior to December 13, 2000. The Court of Appeals held that pre-Mains denials continue not to be subject to any time limitation, as under pre-Mains practice. View "Mandeville v. Gaffney" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court affirmed the judgment of the superior court affirming the decision of the Civil Service Commission ordering Plaintiff's reinstatement to his position as a tenured civil service employee, holding that the Commission's determination that the Town of Brookline lacked just cause to discharge Plaintiff was supported by substantial evidence.Specifically, the Supreme Judicial Court held (1) in analyzing whether an employee was fired without just cause, in violation of basic merit principles, the Commission can consider evidence of discriminatory or retaliatory conduct that is generally addressed in the context of a claim under Mass. Gen. Laws ch. 151B; and (2) the Commission did not exceed its authority or lacked substantial evidence in determining that the Town lacked substantial evidence for its decision. View "Town of Brookline v. Alston" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on the theory of extreme atrocity or cruelty, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Judicial Court held (1) the judge did not err in excluding the third-party culprit evidence proffered by Defendant, and the judge did not commit reversible error by barring Defendant from testifying as to certain statements; (2) the failure to instruct the jury on voluntary intoxication did not create a substantial likelihood of a miscarriage of justice; (3) the evidence presented at trial was sufficient to establish that Defendant committed the offense; and (4) this Court declines to exercise its extraordinary power under Mass. Gen. Laws ch. 278, § 33E to order a new trial or to reduce Defendant's sentence. View "Commonwealth v. Martinez" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court held that the broad eminent domain powers granted to redevelopment authorities by Mass. Gen. Laws ch. 12B, 11(d) include demonstration projects under Mass. Gen. Laws. ch. 121B, 46(f).The Somerville Redevelopment Authority (SRA) took by eminent domain approximately four acres of land from Cobble Hill Center LLC as a demonstration project pursuant to section 46(f). Following the taking, Cobble Hill brought this action asserting that section 46(f) does not authorize takings by eminent domain. The trial judge entered judgment in favor of SRA. The Supreme Judicial Court affirmed, holding (1) the demonstration project plan at issue satisfied the definition of "demonstration" for purposes of section 46(f); and (2) the SRA's taking was a lawful demonstration under section 46(f) and was constitutional. View "Cobble Hill Center LLC v. Somerville Redevelopment Authority" on Justia Law

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The Supreme Judicial Court affirmed the order of the superior court allowing Plaintiff's motion for a preliminary injunction but amended the first numbered paragraph of the order to affirmatively restrain only Turo Inc.'s conduct, holding that the preliminary injunction was properly granted.The Massachusetts Port Authority (Plaintiff) filed suit against Turo, RMG Motors LLC, and John Doe Nos. 1 through 100 (collectively, Defendants) in this dispute over the unregulated pick up and drop off of passengers at the Logan International Airport. At issue on appeal was the superior court judge's order granting a preliminary injunction in favor of Plaintiff that restricted Turo from conducting commercial activity at the airport without written permission from Plaintiff. The Supreme Judicial Court affirmed the order, holding that the judge did not err in issuing the preliminary injunction but that a modification of the terms of the injunction to comply with the requirements of the Communications Decency Act, 47 U.S.C. 230(c)(1) was required. View "Massachusetts Port Authority v. Turo Inc." on Justia Law

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The Supreme Judicial Court reversed Defendant's conviction of two counts of assault and battery by means of a dangerous weapon resulting in serious injury, holding that the trial court judge erred in excluding one of Defendant's experts, and this error was prejudicial.At trial, Defendant argued that he acted in self-defense and that the two men involved in the altercation were motivated to attack him by racial animus. To support his theory, Defendant sought to introduce the testimony of two experts who would testify that the tattoo found on one of the men was affiliated with a group that espoused white supremacist beliefs. The judge excluded both efforts on reliability grounds. The Supreme Judicial Court reversed and remanded the case for a new trial, holding that the trial judge abused his discretion in excluding the testimony of one of the experts, and this error was prejudicial. View "Commonwealth v. Hinds" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the single justice of the court denying Petitioner's petition brought under Mass. Gen. Laws ch. 211, 3, holding that the single justice did not err or abuse her discretion in denying relief.Petitioner brought a personal injury action against Respondent, and the case proceeded to a jury trial. After the close of the evidence but prior to closing arguments, Petitioner indicated that he no longer wished to continue with the trial. After discussing the decision with Petitioner, the judge dismissed the complaint. Petitioner subsequently filed a notice of appeal and then a second notice of appeal. The judge dismissed the first appeal and then struck the second notice of appeal. Petitioner subsequently filed this petition asking the court to declare a mistrial and to order a new trial. The single justice summarily denied the petition. The Supreme Judicial Court affirmed, holding that Petitioner was not entitled to relief on the underlying complaint. The Court then remanded the matter with instructions to process the second notice of appeal. View "Jahm v. Mall at Liberty Tree, LLC" on Justia Law

Posted in: Criminal Law