Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed the denial of Defendant's motion to suppress evidence obtained as a result of a stop, holding that, going forward, the age of a juvenile suspect, if objectively apparent to a reasonable officer, will be part of the totality of the circumstances relevant to whether the juvenile as seized under article 14 of the Massachusetts Declaration of Rights.Minutes after a shooting, two police officers encountered seventeen-year-old Defendant walking on the sidewalk. After attempting to speak with Defendant, one of the officers started to get out of the cruiser, after which Defendant ran. Defendant was charged with murder in the first degree. Defendant filed a motion to suppress. The trial court denied the motion. The Supreme Judicial Court affirmed, holding (1) the trial judge did not abuse his discretion in concluding that the officers had a reasonable, articulable suspicion of criminal activity; (2) a child's age, when known to the officer or objectively apparent to a reasonable officer, is relevant to the question of seizure under article 14; and (3) there was insufficient evidence that the officers knew or should have known prior to his arrest, that Defendant was below the age of eighteen. View "Commonwealth v. Evelyn" on Justia Law

The Supreme Judicial Court established a revised test for a court to determine whether a defendant seeking to suppress evidence based on a claim that a traffic stop violated equal protection principles.The Supreme Judicial Court reversed the judgment of the district court denying Defendant's motion to suppress the evidence seized from the vehicle he was driving, holding that the trial judge abused his discretion in denying the motion to suppress because Defendant produced sufficient evidence to raise a reasonable inference that the stop was racially motivated. In so holding, the Court concluded (1) a defendant seeking to suppress evidence evidence based on a violation of his or her equal protection rights must establish a reasonable inference that the officer's decision to initiate the stop was motivated by race or another protected class; and (2) to raise this inference, the defendant must point out specific facts from the totality of the circumstances surrounding the stop. View "Commonwealth v. Long" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction for murder in the first degree on theories of deliberate premeditation and felony murder, holding that the trial court did not err in denying Defendant's motion to suppress or in introducing at trial Defendant's statements made to investigators.On appeal, Defendant argued that the trial court erred by denying his motion to suppress all the statements he made to investigators while he was questioned at a police station and that the admission of those statements at trial was prejudicial. The Supreme Judicial Court affirmed and declined to exercise its authority under Mass. Gen. Laws ch. 278, 33E to reduce the verdict or to order a new trial, holding (1) the motion judge did not err in denying Defendant's motion to suppress; (2) the trial court did not err in admitting Defendant's statements at trial; and (3) no other relief was appropriate. View "Commonwealth v. Weidman" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction, after a second jury trial, as a joint venturer in vaginal and anal rapes committed by his two coventurers, holding that subjecting Defendant to a second trial did not violate the constitutional protection against double jeopardy.Defendant was indicted on nine counts of forcible rape of a child. Defendant was charged as a principal in three of the rape counts and a joint venturer in three other counts. After a jury trial, Defendant was acquitted on the counts in which he was charged as a principal and all counts alleging oral rape where he had been charged as a joint venturer. The jury was unable to reach a verdict with respect to the remaining counts. At the retrial, the Commonwealth introduced the results of additional DNA tests conducted on the clothing the victim had been wearing. After a second jury trial, Defendant was convicted as a joint venturer in vaginal and anal rapes. The Supreme Judicial Court affirmed the convictions, holding (1) there was no error in retrying Defendant; and (2) the additional DNA evidence should not have been introduced at the second trial, but the error did not prejudice Defendant. View "Commonwealth v. Adams" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction for murder in the first degree and declined to grant extraordinary relief pursuant to Mass. Gen. Laws ch. 278, 33E, holding that there was no basis to set aside or reduce the verdict of murder in the first degree or to order a new trial.Specifically, the Supreme Judicial Court held that the trial judge did not err by (1) refusing to suppress Defendant's statements to police; (2) ruling against Defendant on two juror challenges pursuant to Commonwealth v. Soares, 377 Mass. 461 (1979); (3) excluding third-party culprit evidence; and (4) declining to instruct the jury in accordance with Commonwealth v. Reid, 29 Mass. App. Ct. 537 (1990). View "Commonwealth v. Rosa-Roman" on Justia Law

The Supreme Judicial Court affirmed the order of the trial judge authorizing the disclosure to defense counsel of a discovery letter written by a district attorney describing misconduct by Petitioners, two police officers, that the district attorney obtained through immunized grand jury testimony, holding that the district attorney had a Brady obligation to disclose the exculpatory information to certain unrelated criminal defendants.The district attorney learned through a witness's immunized grand jury testimony that Petitioners knowingly made false statements in police reports that concealed the unlawful use of force by a fellow officer against an arrestee and supported a fake criminal charge of resisting arrest against the arrestee. The district attorney prepared a discovery letter describing Petitioners' misconduct and asked a superior court judge to authorize its disclosure to defense counsel as potentially exculpatory information in unrelated criminal cases where Petitioners might be witnesses. The superior court judge authorized the disclosure. The Supreme Judicial Court affirmed, holding that the prosecutors had a Brady obligation to disclose the exculpatory information to unrelated criminal defendants in cases where a petitioner is a potential witness or prepared a report in the criminal investigation even though that information was obtained in immunized grand jury testimony. View "In re Grand Jury Investigation" on Justia Law

In these consolidated cases, the Supreme Judicial Court held that a delay in providing counsel to Defendants did not entitle them to release from pretrial detention under Lavallee v. Justices in the Hampden Superior Court, 442 Mass. 228 (2004).At Defendants' arraignments, the Commonwealth moved for both of them to be detained before trial pursuant to Mass. Gen. Laws ch. 276, 58A. Both defendants were entitled to appointed counsel for their section 58A hearings because they were found to be indigent. However, due to a shortage of available defense attorneys, there was a delay in the assignment of counsel for Defendants, and their section 58A hearings were continued. When the hearings took place, the judge set bail. Because neither defendant was able to post the required amount both were held in lieu of bail. Defendants filed petitions pursuant to Mass. Gen. Laws ch. 211, 3, arguing that they were entitled to release because their pretrial detention without counsel for more than seven days violated the standards established for timely appointment of defense counsel for indigent criminal defendants in Lavallee. The Supreme Judicial Court denied relief, holding that Lavallee did not create an automatic right to release from pretrial detention for any indigent defendant held more than seven days without counsel. View "Walsh v. Commonwealth" on Justia Law

The Supreme Judicial Court held that the board of registration in medicine may use a sealed criminal record as a basis for discipline but that the board is statutorily prohibited from making the contents of that record available to the public.Petitioner, a physician licensed by the board, was arrested and charged with a misdemeanor count of engaging in sexual conduct for a fee. After the board informed Petitioner that he was under investigation the court dismissed Petitioner's criminal case and Petitioner filed an application to renew his medical license. Thereafter, pursuant to Petitioner's request, a judge in the district court ordered Petitioner's criminal record sealed under Mass. Gen. Laws ch. 276, 100C. Petitioner notified the board of the sealing order and requested that his disciplinary matter be closed. When the board declined to close the matter Petitioner filed an emergency petition for writ of certiorari. The Supreme Judicial Court held that section 100C does not prohibit the board from using a record sealed under the section in its disciplinary proceedings, but it does prohibit the board from publicly disclosing any information gleaned directly from a record sealed under section 100C. View "Doe v. Board of Registration in Medicine" on Justia Law

The Supreme Judicial Court concluded that the existing September 1, 2020 deadline for the receipt of mail-in primary election ballots is constitutional.In response to the COVID-19 pandemic, the Legislature passed an emergency law to increase voting options in the September 1 primary election and the November 3 general election. The act included the additional voting option of voting by mail. For the primary election, voters may apply for a mail-in ballot, so long as their application to vote by mail is received by August 26, and the mail-in primary election ballot is completed and received by local election officials before 8 p.m. on September 1. Plaintiffs argued that the September 1 deadline significantly interferes with the constitutional right to vote. The Supreme Court disagreed, holding that the September 1 deadline for the receipt of mail-in primary election ballots is not unconstitutional. View "Grossman v. Secretary of the Commonwealth" on Justia Law

In this case involving procedures and remedies for impermissible peremptory challenges the Supreme Judicial Court adopted the language of the Federal standard for the first step of a challenge pursuant to Batson v. Kentucky, 476 U.S. 79 (1986), and retired the language of "pattern" and "likelihood" governing the first-step inquiry under Commonwealth v. Soares, 444 U.S. 881 (1979).While incarcerated, Defendant argued on appeal and in pursuing postconviction relief that the trial judge did not appropriately inquire as to whether the prosecutor unconstitutionally struck African-American men from the jury. The Appeals Court determined that the trial judge did not err in deciding not to continue past the first step of the Batson-Soares inquiry. In granting Defendant's petition for writ of habeas corpus, the First Circuit concluded that the trial judge unreasonably applied Federal law. Defendant then filed a motion for a new trial or, in the alternative, for a reduced sentence. The motion judge reduced the verdict under Mass. R. Crim. P. 25(b)(2) and resentenced Defendant. The Supreme Judicial Court vacated the order and remanded for retrial, holding (1) the judge improperly reduced the verdict, and the principles of double jeopardy did not preclude retrying Defendant; and (2) adopting the Federal formulation of the Batson-Soares test will better identify improper peremptory challenges. View "Commonwealth v. Sanchez" on Justia Law