Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree, holding that Defendant failed to demonstrate that his trial counsel was ineffective and that the trial court did not err in denying Defendant's motion for a new trial.In this appeal, which the Supreme Court consolidated with the denial of Defendant's motion for a new trial, Defendant argued that his trial counsel was ineffective for not moving to suppress his optical records and his cell site location information. The Supreme Court affirmed, holding (1) Defendant's trial counsel provided effective assistance; (2) the trial court did not err in denying Defendant's motion for a new trial; and (3) there was no reason to vacate Defendant's conviction or to order a new trial pursuant to Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Gosselin" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions of two counts of murder and other crimes, holding that any error committed during the proceedings below was not prejudicial.Specifically, the Supreme Judicial Court held (1) the trial judge's admission of a DNA expert's testimony regarding a "nonexclusion" result; (2) the trial judge did not err in admitting into evidence charts depicting DNA test results; (3) the prosecutor erred in misstating certain evidence, but the error was not prejudicial; (4) the judge's jury instruction that prior inconsistent statements may not be considered substantively was erroneous, but the error did not prejudice Defendant as to require a new trial; (5) the trial judge did not err in denying Defendant's motion for a new trial on the grounds that a purported courtroom closure during voir dire was unconstitutional; and (6) following plenary review of the record pursuant to Mass. Gen. Laws ch. 278, § 33E, there was no basis for reducing Defendant's sentence on the murder conviction or ordering a new trial. View "Commonwealth v. Lester" on Justia Law

The Supreme Judicial Court vacated Defendant's convictions for operating a motor vehicle while under the influence of alcohol (OUI) causing serious bodily injury and misleading an investigator, holding that errors at trial required that Defendant's convictions be vacated and the matter remanded for a retrial.Specifically, the Supreme Judicial Court held (1) the plain language of the relevant statutes makes clear that blood alcohol level testing shall not be done absent consent, and any nonconsensual testing done at the police's direction is inadmissible; (2) because Defendant's blood draw was performed without Defendant's actual consent, the blood draw was impermissible and the blood alcohol content test results were improperly admitted at trial, and the tainted evidence was not harmless beyond a reasonable doubt; and (3) the trial judge erred by failing to make an independent determination regarding the voluntariness of Defendant's statements and by failing to give a humane practice instruction to the jury, and the error created a substantial risk of a miscarriage of justice. View "Commonwealth v. Bohigian" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree, holding that there was no reversible error in the proceedings below nor reason to exercise the Court's authority under Mass. Gen. Laws ch. 278, 33E.Specifically, the Supreme Judicial Court held (1) the Commonwealth did not violate Defendant's due process rights by omitting evidence that helped Defendant and that countered the prosecutor's theory of the case; (2) error occurred when a lay witness testified that he had previously referred to Defendant as the "guy...who killed my cousin" but the inadmissible evidence did not create a substantial likelihood of a miscarriage of justice; (3) the prosecutor improperly urged the jury to draw an inference of guilt against Defendant due to his courtroom behavior, but the error did not create a substantial likelihood of a miscarriage of justice; (4) there was no error in the jury instructions regarding circumstantial evidence; (5) Defendant's trial counsel did not provide ineffective assistance; and (6) the motion judges did not err in denying the defendant's motions for posttrial discovery. View "Commonwealth v. Moffat" on Justia Law

The Supreme Judicial Court affirmed the order of the juvenile court judge denying a juvenile's motion for relief from sex offender registration, holding that the record below was inadequate for the Court to decide the constitutional issue presented by the juvenile in this case.After the juvenile court judge denied the juvenile's motion to be relieved from his obligation to register as a sex offender the juvenile filed a petition seeking relief under Mass. Gen. Laws ch. 211, 3, arguing that requiring juveniles to register violates due process and constitutes cruel and unusual punishment based on advances in the understanding of the adolescent brain. The Supreme Judicial Court denied relief, holding (1) based on the record, the judge's determination that the juvenile should not be relieved of the obligation to register as a sex offender did not lie outside the bounds of reasonable alternatives; and (2) because of the absence of expert testimony and the failure to properly introduce the scientific studies cited in the judge's written findings, the Court did not have the necessary record to reach the constitutional issue. View "Ernest E. v. Commonwealth" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on a theory of deliberate premeditation and an attempt to suborn perjury and declined to exercise its extraordinary authority under Mass. Gen. Laws ch. 278, 33 E to order a new trial or to reduce the degree of guilt, holding that no prejudicial error occurred in the proceedings below.Specifically, the Supreme Judicial Court held (1) the evidence was sufficient to support Defendant's conviction; (2) the trial court did not err in denying Defendant's motion to suppress cell site location data and admitting that data at trial; (3) the trial judge did not abuse his discretion in allowing into evidence out-of-court statements by Defendant's alleged coventurer and in excluding other evidence concerning that coventurer; (4) the trial judge did not abuse his discretion by allowing the charges against Defendant to be joined for trial; (5) the trial judge did not commit prejudicial error by not giving "missing witness" and Bowden instructions; and (6) improprieties in the prosecutor's closing argument did not create a substantial likelihood of a miscarriage of justice. In addition, the Supreme Judicial Court discerned no reason to order a new trial or to reduce the degree of guilt under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Wilkerson" on Justia Law

In this case, the Supreme Judicial Court responded to a certified question posed by a judge in a federal district court concerning the application of the six-year statute of repose in Mass. Gen. Laws ch. 260, 2B to claims regarding alleged defects in the design and construction of the common areas of a multi-building, multi-phase condominium.The Supreme Judicial Court answered (1) regardless of how many phases of the development there may be or how many buildings are within each phase, where a condominium development is comprised of multiple buildings each building constitutes a discrete improvement for purposes of Mass. Gen. Laws ch. 260, 2B such that the opening of each individual building to its intended use or the substantial completion of the individual building and the taking of possession for occupancy by the owner triggers the statute of repose under section 2B with respect to the common areas and limited common areas of that building; and (2) where a particular improvement is integral to, and intended to serve, multiple buildings the statute of repose begins to run when that discrete improvement is substantially complete and open to its intended use. View "D'Allessandro v. Lennar Hingham Holdings, LLC" on Justia Law

The Supreme Judicial Court vacated the decision of the reviewing board of the Department of Industrial Accidents determining that the Department lacked subject matter jurisdiction over the claim of Mark Mendes, holding that the Commonwealth had jurisdiction over Mendes's claim.Mendes, a Massachusetts resident, entered into an employment contract, performed much of the work, and was injured outside of the Commonwealth. The Department's reviewing board denied and dismissed Mendes's claim for workers' compensation, determining that Massachusetts lacked jurisdiction over the claim because it was neither the place of hire nor the place of injury. The Supreme Judicial Court vacated the board's decision, holding that there were sufficient significant contacts between Massachusetts and Mendes's employment such that the employment relationship was located in Massachusetts. View "Mark Mendes's Case" on Justia Law

The Supreme Judicial Court held that the $1.25 fee cap set forth in Mass. Gen. Laws ch. 262, 41 applies only to a particular notarial act known as "noting," and that the meaning of that section has not been expanded to include all notarial acts.The question at issue in this case arose in connection with a lawsuit in which Plaintiff alleged that Defendants - The UPS Store, Inc., and J&V Logistics LLC, the franchise owner - overcharged him for notary services. Plaintiff alleged violations of Mass. Gen. Laws ch. 262, 41 and Mass. Gen. Laws ch. 93A. Defendants removed the case to the federal district court. Thereafter, Defendants moved to certify to the Supreme Judicial Court the question of whether section 41 applies to all notarial acts, as argued by Plaintiff. The district court certified the question. The Supreme Judicial Court held that Mass. Gen. Laws ch. 262, 41 and 43 to not proscribe fees for acts unrelated to the protest of a negotiable instrumented that, aside from section 41, there are currently no statutes or executive orders that cap fees for any other notarial act. View "Richardson v. UPS Store, Inc." on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court judge in this civil commitment matter, holding that sufficient admissible evidence was presented to warrant an order to civilly commit J.P. for a period not to exceed six months pursuant to Mass. Gen. Laws ch. 123, 7, 8.Southcoast Behavioral Health filed a timely petition for J.P.'s involuntary commitment, alleging that, as a result of mental illness, J.P. presented a risk of harm to others and a substantial risk of harm to himself and that civil commitment was the least restrictive alternative in the circumstances. After a hearing, the judge ordered J.P. civilly committed for a period not to exceed six months. The Supreme Judicial Court affirmed, holding (1) the judge improperly considered certain evidence because it was inadmissible hearsay, but J.P. suffered no prejudice from the admission of this evidence; and (2) there was sufficient evidence presented to support the civil commitment order. View "In re J.P." on Justia Law