Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed the entry of continuance without a finding and immediate dismissal of the criminal case but held that the disposition cannot be imposed in any such future case because, without the imposition of terms and conditions or probation, the continuance without a finding constituted an illegal sentence and that this disposition shall apply prospectively from the date of this decision.Defendant was charged with counterfeit drug possession with intent to distribute and other crimes. Defendant admitted to sufficient facts as to the crime. As to the counterfeit drug charge, the sentencing judge found sufficient facts and entered a continuance without a finding. The Commonwealth filed a motion requesting that the sentencing judge revise or revoke the entry of the continuance without a finding because the order was an "illegal disposition" contrary to Mass. Gen. Laws ch. 278, 18. The judge denied the motion without a hearing. The Supreme Judicial court affirmed, holding (1) because the sentencing judge did not impose any terms or conditions on the record, the continuance without a finding was an illegal disposition; and (2) this holding shall apply prospectively from the date of this decision. View "Commonwealth v. Beverly" on Justia Law

The Supreme Judicial Court declined to remand this case for resentencing, holding that the sentencing judge imposed an illegal sentence by entering a continuance without a finding and immediately dismissing a charge absent any terms and conditions or probation but that this holding shall apply prospectively from the date of this decision.Defendant was charged with five counts, including breaking and entering, and admitted to sufficient facts as to all five counts. The sentencing facts found facts sufficient for a guilty plea and entered a continuance without a finding as to the breaking and entering charge. The judge ordered the dismissal of the charge for 4 p.m. that day and did not set any conditions or terms on the dismissal. The Supreme Judicial Court held (1) the continuance without a finding amounted to an illegal sentence; but (2) this holding applies prospectively from the date of this decision. View "Commonwealth v. Rossetti" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions for murder in the first degree and other crimes, affirmed orders denying Defendant's pretrial and postconviction motions, and declined to grant extraordinary relief pursuant to Mass. Gen. Laws ch. 278, 33E, holding that no reversible error occurred in the proceedings below.Specifically, the Supreme Judicial Court held (1) the trial judge did not err in deciding not to instruct the jury on self defense; (2) although it was error to require that Defendant's testimony take narrative form without his attorney's express prior invocation of Mass. R. Prof. C. 3.3(e), there was no substantial likelihood of a miscarriage of justice arising out of this error; (3) the trial judge did not err in denying Defendant's pretrial motion to dismiss the indictments; and (4) the trial judge properly denied Defendant's pretrial motion to suppress certain statements he made to officers at the police station without the benefit of prior Miranda warnings. View "Commonwealth v. Miranda" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions for murder in the first degree and felony murder and declined to exercise its authority to reduce or set aside the murder verdict, holding that the record revealed no basis to support relief under Mass. Gen. Laws ch. 278, 33E.Specifically, the Supreme Judicial Court held (1) there was no error, constitutional or otherwise, regarding the manner in which defense counsel and the trial judge invoked Mass. R. Prof. C. 3.3 (e), as appearing in 471 Mass. 1416 (2015), and related procedures approved in Commonwealth v. Mitchell, 438 Mass. 535 (2003); (2) the trial court did not err by allowing the testimony of a substitute medical examiner; (3) the trial judge's failure to sever Defendant's trial from that of his codefendant did not result in prejudicial error; and (4) Defendant's conviction of and sentencing for both felony-murder, with attempted armed robbery as the predicate felony, and armed assault with the intent to rob did not violate the double jeopardy clause of the Fifth Amendment. View "Commonwealth v. Leiva" on Justia Law

The Supreme Judicial Court affirmed Defendants' convictions and the orders denying their motions for a new trial and for postconviction relief but remanded the matter of Sheldon Mattis's sentence for an evidentiary hearing, holding that the record was insufficient to address the issue of whether a term of life without the possibility of parole for an individual between the age of eighteen and twenty-two years old violates the prohibition against cruel or unusual punishment.Defendants, Nyasani Watt and Sheldon Mattis, were convicted of murder in the first degree and related crimes. In addition to other claims, Mattis appealed from his mandatory sentence of life without the possibility of parole, arguing that, due to his age of eighteen, the sentence was unconstitutional. The Supreme Judicial Court held (1) there was no prejudicial error in the trial judge's challenged evidentiary rulings; (2) the judge did not err in failing to provide an involuntary manslaughter instruction; (3) remand was required for development of the record with regard to research on brain development after the age of seventeen; (4) the trial court did not err in denying Defendants' motions for a new trial; and (5) there was no reason to grant either defendant extraordinary relief pursuant to Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Watt" on Justia Law

In this case brought by incarcerated individuals challenging the conditions of confinement during the COVID-19 pandemic the Supreme Judicial Court allowed the parole board's motion to dismiss only with respect to the claims of the individuals civilly committed and allowed the Governor's motion to dismiss, holding that the Governor was not liable under the facts alleged.The complaint alleged that by confining Plaintiffs under conditions that put them in grave and imminent danger of contracting the COVID-19 virus and by failing to reduce the incarcerated population, Defendants were violating Plaintiffs' right to be free from cruel and unusual punishment and their right to substantive due process. Further, Plaintiffs alleged that confining persons who have been civilly committed under Mass. Gen. Laws ch. 123, 35 in correction facilities violates the individuals' rights to substantive due process. The Supreme Judicial Court (1) granted the Governor's motion to dismiss, holding that the Governor's presence was not necessary to provide any relief that a court may order in this case; and (2) allowed the parole board's motion to dismiss only with respect to the claims of individuals civilly committed, holding that if Plaintiffs' constitutional claims were to prevail, the parole board would be a logical and necessary party to accomplish a reasonable remedial process. View "Foster v. Commissioner of Correction (No. 2)" on Justia Law

The Supreme Judicial Court denied Plaintiffs' motion for a preliminary injunction enjoining the Department of Correction (DOC) from housing prisoners in facilities where the population exceeds its design-rated capacity and from housing prisoners areas where they must live within six feet of another person, holding that, despite the COVID-19 pandemic, Plaintiffs were unlikely to succeed on the merits of their claim for violations of the Eighth Amendment.Plaintiffs, incarcerated inmates serving sentences or individuals who were civilly committed under Mass. Gen. Laws ch. 123, 35, commenced a class action alleging that their conditions of confinement exposed them to unreasonable risks from the COVID-19 pandemic. Specifically, Plaintiffs alleged that Defendants' failure to take steps to reduce the incarcerated population so as to permit adequate physical distancing constituted cruel and unusual punishment in violation of the Eighth Amendment and violated substantive due process requirements. Plaintiffs sought a preliminary injunction in their claims for unconstitutional conditions of confinement because of the risk of a disease. The Supreme Judicial Court denied the motion, holding that Plaintiffs were unlikely to succeed on the merits of their claim. The Court then transferred the case to the superior court for a final adjudication on the merits. View "Foster v. Commissioner of Correction (No. 1)" on Justia Law

The Supreme Judicial Court affirmed the judgment of a single justice of the court dismissing as moot Petitioner's petition pursuant to Mass. Gen. Laws ch. 211, 3, holding that the single justice did not abuse her discretion.Petitioner was convicted of murder in the first degree and sentenced to life in prison. While he was still in prison, Petitioner filed his Mass. Gen. Laws ch. 211, 3 petition asking the Supreme Judicial Court to order his release because the Department of Correction allegedly failed in its duty to timely release him after granting him medical parole. While Petitioner's petition was pending, Petitioner was released. The single justice thereafter dismissed the petition as moot. The Supreme Judicial Court affirmed, holding that the single justice did not abuse her discretion in not addressing the substantive merits of Petitioner's petition. View "Vazquez v. Superintendent, Massachusetts Correctional Institution, Norfolk" on Justia Law

The Supreme Judicial Court affirmed the judgment of the single justice of the court denying Plaintiffs' complaint for relief in the nature of mandamus and for extraordinary relief pursuant to Mass. Gen. Laws ch. 211, 3, holding that the single justice correctly denied relief on all of Plaintiffs' claims.Each plaintiff is or was a defendant in a post-foreclosure summary process action. After an adverse judgment, each plaintiff was required to post an appeal bond or to make periodic use and occupancy payments during the pendency of each plaintiff's summary process appeal. The appellate division affirmed the bond or use and occupancy order in each case. Plaintiffs then collectively filed this complaint for relief in the nature of mandamus and for extraordinary relief under Mass. Gen. Laws ch. 211, 3 seeking relief from the bond and use and occupancy orders. The single justice denied all substantive relief sought. The Supreme Judicial Court affirmed, holding that Plaintiffs did not demonstrate the absence of an adequate and effective alternative remedy. View "Bigelow v. Massachusetts Courts Promulgator of Official Forms" on Justia Law

The Supreme Judicial Court affirmed a judgment of a single justice of the court denying Petitioner's petition for extraordinary relief pursuant to Mass. Gen. Laws ch. 211, 3, holding that the single justice did not err or abuse his discretion in denying relief.Petitioner sought interlocutory review of an order of the district court denying her motion for summary judgment in an action for damages under the Wage Act, Mass. Gen. Laws ch. 149, 148, 150, arguing that relief was warranted because the motion judgment violated Mass. R. Civ. P. 56 in denying her summary judgment motion and in failing to comply with Mass. R. Civ. P. 56(d). The single justice denied relief. The Supreme Judicial Court affirmed, holding that, under the circumstances, Petitioner did not meet the requirement of S.J.C. Rule 2:21(2). View "Lavoie v. Justice of the District Court Department" on Justia Law