Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court answered a question certified to it by the United States Court of Appeals for the First Circuit, holding that the assets of a self-settled discretionary spendthrift irrevocable trust governed by Massachusetts law are not protected from a reach and apply action by the deceased settlor's creditors.Specifically, the Supreme Judicial Court concluded that, based on the circumstances presented in this case and consistent with the well-established public policy of the Commonwealth, when a settlor creates a self-settled spendthrift irrevocable trust that is governed by Massachusetts law and that allowed unlimited distributions to the settlor during his lifetime, and a judgment-creditor's cause of action accrues prior to the settlor's death, a judgment-creditor of the settlor's estate may reach and apply the trust's assets after the settlor's death. View "De Prins v. Michaeles" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree but dismissed Defendant's convictions of possession of ammunition, holding that those convictions were duplicative of the convictions of possession of a loaded firearm.Defendant was convicted of murder in the first degree and on twenty-four other indictments that included various firearms charges and other charges related to the injuries Defendant inflicted on victims when he fired shots at a New Year's Eve house party. The Supreme Judicial Court affirmed, holding (1) there was not a substantial likelihood of a miscarriage of injustice even though the verdict slip indicated that the jury found Defendant guilty of both murder in the first degree and murder in the second degree; (2) two convictions of possession of ammunition must be dismissed because they were lesser included offenses of Defendant's convictions of possession of a loaded firearm; and (3) this Court declines to exercise its extraordinary power under Mass. Gen. Laws ch. 278, 33E to order a new trial or to reduce the degree of guilt. View "Commonwealth v. Phuon" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of two counts of possession of child pornography, in violation of Mass. Gen. Laws ch. 272, 29C, holding that the information in the search warrant was sufficient for a magistrate to have found probable cause.Seven months after Defendant's alleged illegal activity, a police trooper obtained a warrant authorizing a search of all computer systems and digital storage devices located within Defendant's residence for evidence of child pornography. During the execution of a search warrant Defendant's laptop computer and flash drive were seized. On appeal from his conviction, Defendant argued that the passage of seven months between the alleged upload of child pornography and the application for a search warrant rendered the warrant stale so that it lacked probable cause. The Supreme Judicial Court affirmed, holding that the motion judge did not err in finding that the information in the warrant affidavit was not stale when the warrant was filed. View "Commonwealth v. Guastucci" on Justia Law

The Supreme Judicial Court affirmed the judgment of the single justice of the court denying Petitioner's petition for extraordinary relief pursuant to Mass. Gen. Laws ch. 211, 3, holding that the extraordinary remedy of general superintendence was not required in this matter.In his petition, Petitioner claimed that Respondents had engaged in a conspiracy to deprive him of due process in his criminal matter and in his efforts to apply for criminal complaints. The single justice denied the petition without a hearing. The Supreme Judicial Court affirmed, holding that Petitioner had adequate alternative avenues to seek the relief he requested in connection with the criminal case against him. View "Roberts v. Hingham Division of the District Court Department" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions of carrying a firearm without a license and of possessing a loaded firearm, holding that no prejudicial error occurred in the proceedings below.Specifically, the Supreme Judicial Court held (1) the motion judge did to err in denying Defendant's motion to suppress the firearm; (2) there was sufficient evidence to support the conviction of possession of a loaded firearm; (3) the trial court's failure to instruct the jury that Defendant had to know that the firearm was loaded did not create a substantial risk of a miscarriage of justice; and (4) there was no error in the prosecutor's closing arguments. View "Commonwealth v. Silvelo" on Justia Law

The Supreme Judicial Court affirmed the decision of the superior court affirming the decision of the Contributory Retirement Appeal Board (CRAB) that Appellant was not entitled to retirement benefits calculated based on her salary for the years that she worked as a contract employee, holding that the superior court did not abuse its discretion.After Appellant retired she requested that her benefit amount be based on her compensation during the purchased years of creditable contract employment with the State rather than her lower-paid years as a regular State employee. CRAB ruled against Appellant's request, and the superior court affirmed. The Supreme Court affirmed, holding (1) Appellant did not meet the statutory definition of "employee" for purposes of the retirement system in the years that she worked as a contract employee; and (2) therefore, CRAB properly determined that compensation received during years for which credit in the State retirement system is purchased is not regular compensation and may not be used to calculate a member's pension benefit. View "Young v. Contributory Retirement Appeal Board" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree and the denial of his motion for a new trial and declined to exercise its authority under Mass. Gen. Laws ch. 278, 33E to reduce the verdict or order a new trial, holding that none of the errors during trial created a substantial likelihood of a miscarriage of justice.A jury found Defendant guilty of murder in the first degree on the theories of deliberate premeditation and extreme atrocity or cruelty. The Supreme Judicial Court affirmed, holding (1) trial counsel erred by failing to engage a medical expert to opine on the voluntariness of Defendant's statements after surgery and on whether his waiver of Miranda rights was knowing and voluntary, but the error did not create a substantial likelihood of a miscarriage of justice; (2) trial counsel was not ineffective for conceding certain points during closing argument; and (3) the trial judge erred in instructing the jury as to some issues, but the error did not create a substantial likelihood of a miscarriage of prejudice. View "Commonwealth v. Richards" on Justia Law

The Supreme Judicial Court vacated Defendant's conviction of murder in the first degree on the theory of extreme atrocity or cruelty, holding that there was a substantial likelihood of a miscarriage of justice arising from the application of the model jury instructions regarding criminal responsibility to the particular facts of this case.On issue at trial was whether the Commonwealth had proved beyond a reasonable doubt that Defendant was criminally responsible for the killing of a patient at the psychiatric ward of the University of Massachusetts Memorial Medical Center, where Defendant was also a patient. The Supreme Judicial Court vacated the convictions, holding that, in view of the substantial evidence that Defendant had a mental disease or defect and that he lacked substantial capacity at the time of the killing, there was a substantial likelihood of a miscarriage of justice arising from the risk of the jury's having misunderstood the model jury instructions. The Court also provisionally revised its model jury instructions regarding criminal responsibility to address what it concluded as a problematic risk of confusion. View "Commonwealth v. Dunphe" on Justia Law

The Supreme Judicial Court vacated the verdict of murder in the first degree and the sentence imposed in this case and remanded the matter to the superior court with directions to enter a verdict of guilty of murder in the second degree and to sentence Defendant accordingly, holding that a verdict of murder in the second degree was the most just verdict in this case.After a jury trial, Defendant was convicted of murder in the first degree on the theory of extreme atrocity or cruelty and sentenced to life without the possibility of parole. The Supreme Judicial Court vacated the conviction, holding (1) this Court's jury instructions regarding all of the extreme atrocity or cruelty factors set forth in Commonwealth v. Cunneen, 389 Mass. 216, 227 (1983) prospectively to more closely comport with the meaning given to the term "extreme atrocity or cruelty" are hereby revised and included in this opinion; and (2) based on the evidence of extreme atrocity or cruelty in this case, this Court exercises its authority under Mass. Gen. Laws ch. 278, 33E to reduce the degree of guilt to murder in the second degree, which, in light of the facts of this case, is a verdict more consonant with justice. View "Commonwealth v. Castillo" on Justia Law

The Supreme Judicial Court reversed the judgment of the district court finding that Defendant violated a special condition of probation and vacating the findings that Defendant violated his conditions of probation, holding that Defendant's actions were not prohibited by his probation condition.A district court judge found that Defendant, a self-employed home improvement contractor, violated a special condition of probation because he did not report as a work address on a sex offender registration form the home in Lynn where he was doing repair work. The judge also found that Defendant violated the special condition of probation that he not "work...with children" because there was an infant in the home where he worked. The Supreme Judicial Court reversed, holding (1) Defendant's "work address" was his home address for sex offender registration purposes; and (2) Defendant did not "work with children" in replacing a gutter or restoring exterior woodwork. View "Commonwealth v. Harding" on Justia Law