Justia Massachusetts Supreme Court Opinion Summaries

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The Supreme Judicial Court affirmed the judgment of a single justice of the court granting the Commonwealth's petition under Mass. Gen. Laws ch. 211, 3 and ordering that a certain superior court judge be recused from acting on Defendant's postjudgment motion to dismiss the indictments against him or for a new trial in his criminal case, holding that the single justice did not err or abuse her discretion.Defendant was convicted of murder in the first degree. The Supreme Judicial Court remanded the case for consideration of whether Defendant was prejudiced by trial counsel's potential conflicts of interest. On remand, Defendant moved to dismiss the indictments against him or for a new trial on the basis of Brady violations. The motion judge raised the question whether she could be impartial because the prosecutor had since been appointed as a superior cour judge and was now her judicial colleague. The Commonwealth subsequently filed a motion in support of recusal. The judge denied the motion, concluding that she could be fair and impartial. The Commonwealth filed a Mass. Gen. Laws ch. 211, 3 petition. A single justice allowed the petition. The Supreme Judicial Court affirmed, holding that the prudent and legally correct result under the circumstances was for the judge to recuse herself. View "Commonwealth v. Cousin" on Justia Law

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The Supreme Judicial Court affirmed the judgment of a single justice of the court denying Petitioner's complaint for relief in the nature of mandamus and for extraordinary relief under Mass. Gen. Laws ch. 211, 3, holding that the single justice did not err or abuse her discretion in denying relief.On March 31, 2017, judgment entered against Petitioner in the underlying superior court case. Petitioner filed a motion to vacate the judgment. After the motion to vacate was denied Petitioner filed a motion for reconsideration and a motion to recuse. Both motions were denied. Petitioner then filed her complaint for relief in the nature of mandamus and for extraordinary relief pursuant to Mass. Gen. Laws ch. 211, 3. The single justice denied relief. The Supreme Judicial Court affirmed, holding that where Petitioner had an adequate alternative avenue to obtain the relief sought - an appeal to the Appeals Court - and chose not to pursue that avenue, Petitioner was not entitled to invoke the extraordinary relief set forth in Mass. Gen. Laws ch. 211, 3. View "Harrington v. Deutsche Bank National Trust Co." on Justia Law

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In this action where the trial court allowed Defendant's special motion to dismiss, the Supreme Judicial Court held that Defendant was entitled to appellate attorney's fees under Mass. Gen. Laws ch. 184, 15(c).Plaintiffs and Defendant executed a written offer to purchase certain property. When discussions related to the purchase and sale agreement were unsuccessful Defendant notified Plaintiffs that it could not make the deal work. Plaintiffs commenced this action alleging breach of contract and other claims. Plaintiffs also applied for a memorandum of lis pendens, which was approved. Defendant filed a motion to dissolve the lis pendens and a special motion to dismiss the action. A judge denied the motion to dissolve the lis pendens but allowed the special motion to dismiss. The Appeals Court affirmed the judgment of dismissal but denied Defendant's request for appellate attorney's fees and costs. The Supreme Judicial Court reversed in part, holding that Defendant was entitled to an award of appellate attorney's fees and costs. View "DeCicco v. 180 Grant Street, LLC" on Justia Law

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The Supreme Judicial Court vacated certain portions of a trial judge's nondisparagement orders issued to the parties in this case in an attempt to protect the psychological well-being of the parties' minor child, holding that the nondisparagement orders here operated as an impermissible prior restraint on speech.After Mother filed for divorce from Father, Mother filed a motion for temporary orders, including a request that the judge prohibit Father from posting disparaging remarks about her and the ongoing litigation on social media. The judge issued temporary orders that included nondisparagement provisions against both parties. Thereafter, Mother filed a complaint for civil contempt alleging that Father violated the first order. A different judge declined to find contempt on the ground that the first order, as issued, constituted an unlawful prior restraint of speech in violation of Father's constitutional rights. The Supreme judicial Court agreed, holding that the nondisparagement orders were unconstitutional. View "Shak v. Shak" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on theories of deliberate premeditation and extreme atrocity or cruelty and declined to exercise its power pursuant to Mass. Gen. Laws ch. 278, 33E to reduce the conviction to manslaughter, holding that there was no reversible error in the proceedings below.Specifically, the Supreme Judicial Court held (1) the trial judge did not err by denying Defendant's requests for a jury instruction pursuant to Commonwealth v. Croft, 345 Mass. 143 (1962); (2) the trial judge did not err by denying Defendant's motions for a required finding of not guilty under Croft because a rational jury could have found that Defendant was guilty of murder in the first degree on both the theories of premeditation and extreme atrocity or cruelty; and (3) there was no basis for reducing Defendant's sentence or ordering a new trial. View "Commonwealth v. Tavares" on Justia Law

Posted in: Criminal Law
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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. 278E to reduce Defendant's conviction to murder in the second degree, holding that Defendant was not entitled to relief on any of his allegations of error.Defendant was convicted of murder in the first degree on the theory of felony-murder. Defendant filed a motion for a new trial, which was denied. The Supreme Judicial Court affirmed, holding (1) Defendant's motion for a new trial was correctly denied because Defendant was not prejudiced by counsel's ineffective assistance; (2) this Court declines to extend the reach of the Court's holding in Commonwealth v. Brown, 477 Mass. 805 (2017), to Defendant's case; and (3) trial judge erred when he declined Defendant's request that the jury be instructed on the elements of voluntary and involuntary manslaughter, but the error was not prejudicial in the context of the judge's other instructions. View "Commonwealth v. Martin" on Justia Law

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The Supreme Judicial Court affirmed Defendant's convictions and the decision of the Appeals Court denying Defendant's motion to vacate the entry of his appeal from his convictions in that court and to have the case entered directly in the Supreme Judicial Court, holding that a direct appeal from the third conviction of a habitual offender pursuant to Mass. Gen. Laws ch. 279, 25(b) may be entered in the Appeals Court.Defendant was indicted for serious felonies arising from a brutal attack and rape. In addition to charging the specific felony, each indictment also alleged that the sentence for that felony should be enhanced pursuant to the habitual criminal provision Mass. Gen. Laws ch. 279, 25(a) or the habitual offender provision of section 25(b), or both. After he was convicted, Defendant moved to have the case entered directly in the Supreme Judicial Court. The Appeals Court denied the motion. The Supreme Judicial Court affirmed Defendant's convictions, holding (1) this direct appeal was entitled to the unique review prescribed by Mass Gen. Laws ch. 278, 33E, and the Appeals Court may conduct such section 33E review; (2) Defendant was not impermissibly allowed to waive his right to a jury trial on the sentencing enhancement provisions of the indictments; and (3) Defendant was not entitled to reversal of his convictions on any other ground. View "Commonwealth v. Billingslea" on Justia Law

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The Supreme Judicial Court dismissed Plaintiff's complaint seeking relief in the nature of mandamus, holding that mandamus relief did not lie with respect to Plaintiff's challenges to discretionary decisions of the superior court.Plaintiff's requests for relief related to postconviction motions and other requests Plaintiff made in a criminal proceeding in the superior court to withdraw his guilty plea. Plaintiff requested several clarifications and that the Court provide a "speedy remedy" for other alleged instances of inaction or misconduct by the superior court in failing to provide relief. The Supreme Judicial Court denied relief, holding that Plaintiff failed to make a showing that alternative avenues of relief were inadequate. View "In re Burnham" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court affirmed the judgment of a single justice of the court denying Petitioner's petition for extraordinary relief under Mass. Gen. Laws ch. 211, 3, holding that the single justice neither erred nor abused her discretion in denying relief.Petitioner primarily sought relief from a superior court judgment revoking his probation and imposing a suspended sentence. In his petition, Petitioner argued that the superior court's reliance on his mental health issues and treatment in refusing to re-probate him violated the Federal Americans with Disabilities Act. The single justice denied relief. The Supreme Judicial Court affirmed, holding that Petitioner's claims were appropriately raised in a direct appeal from the revocation of his probation. View "Burnham v. Commonwealth (No. 1)" on Justia Law

Posted in: Criminal Law
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In this case regarding the mitigation of the spread of COVID-19 in the Commonwealth's prison decision the Supreme Judicial Court affirmed its prior decision, issued on April 3, 2020, as to the extent of the Court's constitutional authority to stay final sentences absent an ongoing challenge to the underlying conviction or a violation of constitutional rights, holding that the global stays of sentences sought by Petitioners would co-opt executive functions in ways that are not permitted by article 30 of the Massachusetts Declaration of Rights.Petitioners asked the Supreme Judicial Court to reconsider its determination that neither the Court's inherent judicial authority nor its superintendence authority permitted a judge to stay a final sentence that is being served, absent a pending appeal or a motion for a new trial, without violating separation of powers principles under article 30. Petitioners further challenged the court's order with respect to reporting requirements. The Supreme Judicial Court affirmed its prior decision but concluded that some of the requested relief as to additional reporting requirements should be allowed, and accordingly issued a revised Appendix B. View "Committee for Public Counsel Services v. Chief Justice of the Trial Court (No. 2)" on Justia Law