Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court answered three questions reported by the juvenile court judge regarding waiver, evidentiary rules, and discovery procedures for hearings conducted under the procedures set forth in Wallace W. v. Commonwealth, 482 Mass. 789 (2019).Juvenile allegedly committed a major misdemeanor against another minor, followed by a minor misdemeanor against the same victim in a separate incident. The Commonwealth moved for a Wallace W. hearing to prove the greater offense, after which the juvenile court judge reported questions of law to the Supreme Court. The Supreme Court concluded (1) the Commonwealth may proceed directly to trial on the greater offense that preceded the first offense, but the Commonwealth may not arraign on the minor misdemeanor until it proves the greater offense; (2) a juvenile's failure to move for a prearraignment Wallace W. hearing on the first offense does not provide subject matter jurisdiction over the first offense; (3) the evidentiary rules laid out in Commonwealth v. During, 407 Mass. 108 (1990), apply to Wallace W. hearings; and (4) notice of the alleged violation and some exchange of discovery are required prior to Wallace W. proceedings. View "Commonwealth v. Nick N." on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions for murder in the first degree on the theory of felony murder and other crimes, holding that there was no prejudicial error in the proceedings below.Specifically, the Supreme Judicial Court held (1) several challenged statements made by the prosecutor in his closing argument did not constitute prejudicial error; (2) the trial judge did not err by denying Defendant's request for a voluntary manslaughter instruction based on self-defense, reasonable provocation, or sudden combat; and (3) this Court declines to exercise its authority under Mass. Gen. Laws ch. 278, 33E to reduce the verdict or order a new trial on the grounds that Defendant was only nineteen years old at the time of the murder. View "Commonwealth v. Tate" on Justia Law

The Supreme Judicial Court affirmed the judgment of a single justice of the court denying Petitioner's petition filed pursuant to Mass. Gen. Laws ch. 211, 3 seeking relief from a superior court judge's order denying his motion to continue the third day of an evidentiary suppression hearing, holding that the single justice did not err or abuse his discretion.At issue before the single justice was whether the trial judge's directive to Petitioner to make a choice whether to appear for an evidentiary hearing in person or via video conference was sufficiently important and extraordinary as to warrant the exercise of the Supreme Judicial Court's extraordinary power pursuant to Mass. Gen. Laws ch. 211, 3. The Supreme Judicial Court held that the single justice did not err or abuse his discretion in denying Petitioner's petition. View "Malary v. Commonwealth" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions for murder in the first degree by deliberate premeditation and of unlawful possession of a firearm, holding that a new trial was not required because there was no error and that there was no reason for the Court to exercise its authority under Mass. Gen. Laws ch. 278, 33E to reduce the verdict of murder in the first degree.Specifically, the Supreme Judicial Court held (1) the trial judge did not err by declining to give a requested instruction on self-defense; (2) the trial judge did not abuse his discretion by allowing the prosecutor to introduce prior bad act evidence; (3) the prosecutor's remarks in her opening statement and closing argument did not create a substantial likelihood of a miscarriage of justice; (4) trial counsel provided constitutionally effective assistance; and (5) a new trial was not warranted based on purported newly discovered evidence. View "Commonwealth v. Teixeira" on Justia Law

The Supreme Judicial Court vacated the judgments entered against Defendant in this criminal case, holding that the trial judge abused his discretion in excusing a juror who claimed to be unable to begin deliberations anew after the discharge of another juror.A jury convicted Defendant of murder in the first first degree on a theory of felony murder, as well as assault and battery by means of a dangerous weapon causing serious bodily injury and possession of a firearm. On appeal, Defendant argued that the motion judge erred in denying his motion to suppress and that the trial judge erred in excusing a juror. The Supreme Judicial Court vacated the judgments entered against Defendant, holding (1) the trial court did not err in denying Defendant's motion to suppress; but (2) the trial court's discharge of the juror in question was error, and the error was prejudicial to Defendant. View "Commonwealth v. Williams" on Justia Law

The Supreme Judicial Court held that 120 Code Mass. Regs. 200.08(3)(c) (regulation), which concerns parole eligibility for inmates sentenced to a prison term that runs consecutive to a life sentence, is contrary to the plain terms of the statutory framework governing parole and is thus invalid.Plaintiffs, two inmates who were serving life sentences for murders committed when they were juveniles, sought declaratory relief invalidating the regulation. The superior court granted summary judgment in favor of the parole board, finding the regulation to be valid. The Supreme Judicial Court reversed, holding that by exempting sentences consecutive to a life sentence from the process often referred to as the "aggregation rule," the regulation contravenes the plain meaning of Mass. Gen. Laws ch. 127, 130 and 133. View "Dinkins v. Massachusetts Parole Board" on Justia Law

The Supreme Judicial Court vacated the orders of the juvenile court judge requiring the Department of Youth Services (DYS) to credit the time that two youthful offenders spent detained in DYS custody prior to being adjudicated against their postadjudication confinement, holding that youthful offenders are not entitled to preadjudication detention credit like prisoners.Defendants were indicted as youthful offenders and held without bail in DYS custody. The judge committed each defendant to DYS custody until the age of twenty-one and ordered DYS to credit the time each spent detained in DYS custody prior to being adjudicated. The Supreme Judicial Court vacated the orders requiring preadjudication credit, holding that Mass. Gen. Laws ch. 218, 59 does not authorize a juvenile court judge to order preadjudication detention credit for youthful offenders pursuant to Mass. Gen. Laws ch. 279, 33A, which applies to criminal defendants. View "Commonwealth v. Terrell" on Justia Law

The Supreme Judicial Court vacated the trial judge's order allowing Defendant's motion to suppress evidence found on Defendant's cell phone and remanded the case to the superior court for further rulings regarding partial suppression, holding that there was probable cause to search Defendant's cell phone and that the search of the phone was not sufficiently particular because it lacked any temporal limit.When Defendant was arrested in connection with a fatal shooting police officers obtained a warrant to search Defendant's cell phone for evidence related to the crime. The judge allowed Defendant's motion to suppress the cell phone evidence, ruling that the warrant had issued without probable cause because it lacked a sufficient nexus between the murder and Defendant's cell phone and noting that the search was not limited in time. The Supreme Judicial Court vacated the suppression order, holding (1) there was probable cause to search Defendant's cell phone; and (2) because the record was silent with respect to the dates of the Commonwealth's proposed evidence, remand was required for a determination of whether the evidence would have fallen within a reasonable temporal limit. View "Commonwealth v. Snow" on Justia Law

The Supreme Judicial Court held that this action against Uber Technologies, Inc. and Easier, LLC (collectively, Uber) was not arbitrable because there was no enforceable agreement between Uber and Plaintiffs.Plaintiffs brought this action under Mass. Gen. Laws ch. 272, 98A claiming that three Uber drivers refused to provide one plaintiff with rides because he was blind and accompanied by a guide dog. Citing a provision in Uber's cellular telephone application, which Plaintiffs had used to register with Uber, Uber moved to compel arbitration. The judge granted the motion. The arbitrator ruled in favor of Uber on all claims. Thereafter, the United States Court of Appeals for the First Circuit held in Cullinane v. Uber Technologies, Inc., 893 F.3d 53 (1st Cir. 2018) that Uber's registration process did not create a contract. Thereafter, the judge reversed his decision granting the motion to compel arbitration, concluding that there was no enforceable contract requiring arbitration. The Supreme Judicial Court remanded the case, holding (1) Uber's terms and conditions did not constitute a contract with Plaintiffs; and (2) therefore, Uber could not enforce the terms and conditions against Plaintiffs, including the arbitration agreement. View "Kauders v. Uber Technologies, Inc." on Justia Law

The Supreme Judicial Court held that certain materials requested and received by the office of the district attorney for the Suffolk district from the Federal Bureau of Investigation (FBI) related to a fatal shooting by federal and state law enforcement officials were exempt from disclosure under Mass. Gen. Laws ch. 4, 7(f).After Usaamah Rahim was killed, the district attorney opened an investigation into his death, aided by various materials provided by the FBI. Plaintiff later filed a public records request seeking documents related to Rahim's death. When the district attorney refused to provide access to the FBI materials Plaintiff sued the district attorney seeking a declaration that the FBI records were public records that must be produced under Mass. Gen. Laws ch. 66, 10. The judge granted summary judgment for the district attorney, concluding that the FBI materials were not public records. The Supreme Judicial Court held (1) the FBI materials qualified as public records under the public records law; (2) the materials were not exempt from disclosure under Mass. Gen. Laws ch. 4, 7(a) but some materials qualified for exemption under Mass. Gen. Laws ch. 4, 7(f); and (3) the remainder of the materials must be remanded to determine whether exemption (f) applies. View "Rahim v. District Attorney for the Suffolk District" on Justia Law