Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed the judgment of a single justice of the court denying Petitioner's petition filed pursuant to Mass. Gen. Laws ch. 211, 3 seeking relief from his sentence imposed as a result of a probation violation as well as from new charges, holding that the single justice did not err or abuse his discretion in denying relief.In 2018, while serving the probationary portion of a sentence he received in 2016, Petitioner was charged with new crimes. Petitioner stipulated to the probation violation as well as to dangerousness. Petitioner then filed his Mass. Gen. Laws ch. 211, 3 petition, arguing that several of his constitutional rights had been violated. The single justice denied the petition without a hearing. The Supreme Judicial Court affirmed, holding that relief was properly denied where Petitioner failed to demonstrate the absence or inadequacy of other remedies. View "Sandman v. Commonwealth" on Justia Law

The Supreme Judicial Court affirmed the judgment of the county court denying Petitioner's petition for relief under Mass. Gen. Laws ch. 211, 3, holding that the single justice did not err or abuse his discretion in denying Petitioner's request.The Court noted that none of the materials Petitioner filed in connection with his petition established any basis for relief. Further, the Court determined that the dismissal of each case in the superior court was subject to appeal to the appeals court in the ordinary process. In addition to denying relief the Court ordered the clerk of the county court not to accept any further filings from Petitioner in this case. View "Cooper v. CVS Pharmacy" on Justia Law

The Supreme Judicial Court vacated the motion judges' denial of two juveniles' motions to dismiss and remanded these matters to the juvenile court with directions to dismiss each case, holding that the amended definition of "delinquent child" should be applied retroactively to cases pending on July 12, 2018.On or after July 12, 2018, as a result of the enactment of St. 2018, ch. 69, a child who commits an offense before the age of twelve or who commits an infraction or a first offense of a misdemeanor for which the punishment is a fine or imprisonment for not more than six months can no longer be adjudicated a "delinquent child." These cases concerned juveniles who allegedly committed offenses before July 12, 2018 but whose cases remained pending before the juvenile court on or after that date. The juveniles filed motions to dismiss the charges against them on the grounds that the Act's definition of "delinquent child" should apply retroactively to their cases. The motion judges denied the motions. The Supreme Judicial Court granted the juveniles' interlocutory petitions for extraordinary relief pursuant to Mass. Gen. Laws ch. 211, 3, holding that the juveniles in these cases were not subject to the Juvenile Court's jurisdiction. View "Lazlo L. v. Commonwealth" on Justia Law

In this, the second of two cases decided today involving Wayne Chapman, the Supreme Judicial Court affirmed the judgment of a single justice of the Court denying Petitioners' petition for relief under Mass. Gen. Laws ch. 211, 3, in which they sought to enjoin Chapman's release from the Massachusetts Treatment Center, holding that Petitioners were not entitled to they relief they sought.After two qualified examiners opined that Chapman was no longer sexually dangerous Petitioners, individuals who were enrolled in the victim notification registry for Chapman, applied for emergency relief in the county court seeking to enjoin Chapman's release. The single justice denied the petition. The Supreme Judicial Court affirmed, holding (1) Petitioners did not have standing to assert the majority of the claims they made; and (2) even if Petitioners' claim that they were not given proper advance of Chapman's imminent discharge, the claim would not entitle Petitioners to an order enjoining Chapman's release. View "In re Chapman" on Justia Law

The Supreme Judicial Court affirmed the superior court judge's order allowing Wayne Chapman's petition for release from civil commitment as a sexually dangerous person, holding that Defendant was not required to remain civilly committed after neither of two qualified examiners had concluded that Defendant was no longer sexually dangerous.When Chapman had approximately one month remaining until his anticipated release from prison the Commonwealth filed a petition to commit Chapman as a sexually dangerous person beyond the term of his criminal sentence under the current version of Mass. Gen. Laws ch. 123A. After trial, Chapman was found to be sexually dangerous and committed to the treatment center for an indeterminate period. Chapman then filed petitions for discharge from civil commitment under chapter 123A, section 9, including the one at issue here. Two qualified examiners offered the opinion that Chapman was no longer sexually dangerous. Chapman then moved for a discharge. The superior court judge, relying on Johnstone, petitioner, 453 Mass. 544, 553 (2009), allowed Chapman's motion. The Supreme Judicial Court affirmed, holding (1) Johnstone was correctly decided, and the principle of stare decisis counsels in favor of adherence to this settled precedent; and (2) where both qualified examiners concluded that Defendant was not sexually dangerous, discharge was appropriate. View "Chapman, petitioner" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions of murder in the first degree on the theories of felony-murder and extreme atrocity or cruelty and declined to grant extraordinary relief pursuant to Mass. Gen. Laws ch. 278, 33E, holding that there was no reason to grant a new trial or to either reduce or set aside the verdict.Specifically, the Court held (1) Defendant failed to show actual juror prejudice by way of pretrial publicity; (2) the judge did not abuse his discretion in admitting fingerprint evidence because the evidence was properly authenticated; (3) trial counsel did not provide ineffective assistance; and (4) the prosecutor's statements during closing argument did not amount to reversible error. View "Commonwealth v. Mack" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of armed robbery and murder in the first degree and declined to exercise its authority under Mass. Gen. Laws ch. 278, 33E to reduce the verdict or to order a new trial, holding that there was no basis upon which to order a new trial or to reduce the degree of guilt.Specifically, the Court held (1) the trial judge did not abuse its discretion in allowing the jurors' request for a magnifying glass during deliberation; (2) the jury instruction on circumstantial evidence and inferences did not unconstitutionally diminish the Commonwealth's burden of proof or violate Defendant's due process rights; and (3) the trial court did not err in permitting Defendant's coworker to testify to Defendant's statement that, if he were to break into the neighbors' house, he would kill the neighbors. View "Commonwealth v. Silva" on Justia Law

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 extraordinary authority to afford relief under Mass. Gen. Laws ch. 278, 33E, holding that there was no error in the proceedings below warranting a new trial.On appeal, Defendant argued that, given his compromised medical and emotional state, the statements he made to police while he was in the hospital should have been suppressed and that the court should reduce the verdict to murder in the second degree. The Supreme Judicial Court affirmed the conviction, holding that no reversible error occurred in the proceedings below. View "Commonwealth v. Rivera" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial judge denying Defendant's motion for a new trial, holding that a defendant's waiver of his right to a jury of six persons need not be in writing as long as the trial judge ensures, by way of colloquy, that the defendant's decision to proceed is made knowingly and voluntarily.Defendant was convicted of cruelty to animals. During trial, one of the six jurors was excused from service. After conducting a colloquy, the judge found that Defendant knowingly and voluntarily waived his right to a jury of six persons, and the trial continued with five jurors. On appeal, Defendant argued that the trial judge erred in denying his motion for a new trial on the grounds that his waiver was invalid because it was not in writing pursuant to Mass. R. Crim. P. 19(b). The Supreme Judicial Court affirmed, holding that Defendant's waiver to his right to a six-person jury was valid. View "Commonwealth v. Bennefield" on Justia Law

The Supreme Judicial Court reversed a lower court judge's order of execution on the fifth agreement for judgment between Y.A., an alleged victim of domestic violence, and the Boston Housing Authority (BHA), a covered housing provider, holding that the motion judge failed to consider whether domestic violence contributed to Y.A.'s failure to make the agreed-upon payments.The Housing Court found that Y.A.'s failure to make required payments set forth in the parties' agreement constituted a violation of a material term of the agreement. The judge made no reference to Y.A.'s allegations of an abusive relationship in his findings. The Supreme Judicial Court remanded the matter to the Housing Court for further proceedings, holding that where a judge is given reason to believe that domestic violence is or might be relevant to a landlord's basis for eviction, the judge must ensure that the judge has sufficient evidence to make a determination whether the tenant is entitled to protections under the federal Violence Against Women Act (VAWA), 34 U.S.C. 12291 et seq., and such a determination must be supported by findings. View "Boston Housing Authority v. Y.A." on Justia Law