Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed Defendant's convictions and the order denying his motion for a new trial and further declined to reduce the verdict of murder in the first degree to a lesser degree of guilt or to set aside the convictions under Mass. Gen. Laws ch. 278, 33E, holding that there was no prejudicial error in the proceedings below.Defendant was convicted of murder in the first degree on the theories of deliberate premeditation, extreme atrocity or cruelty, and felony-murder. The Supreme Judicial Court affirmed Defendant's convictions and the order denying his motion for a new trial, holding (1) the district court did not err in denying Defendant's motion to suppress his statements to police; (2) the trial judge did not err by declining to give a humane practice instruction sua sponte or by declining to provide the jury with complete instructions on joint venture; (3) the trial judge did not err in excluding certain hearsay evidence; and (4) the judge did not err in denying Defendant an evidentiary hearing on his motion for a new trial. View "Commonwealth v. Amaral" on Justia Law

The Supreme Court vacated the judgments entered against Defendant and remanded this case for further proceedings, holding that the dismissal of a juror was prejudicial error and that there was sufficient evidence to survive Defendant's motion for required findings of not guilty.A jury found Defendant guilty of multiple charges relating to the illegal possession and improper storage of firearms and ammunition. During deliberations, a juror informed a court officer that she could not continue to deliberate. After a colloquy with the juror, the judge discharged the deliberating juror and replaced her with an alternate juror. Ninety minutes later, the jury found Defendant guilty. The Appeals Court affirmed. The Supreme Court vacated Defendant's convictions, holding (1) the juror was discharged for reasons that were not purely personal to the juror, and her dismissal was prejudicial error; and (2) the trial judge did not err in denying Defendant's motion for required findings of not guilty. View "Commonwealth v. Tiscione" on Justia Law

The Supreme Judicial Court vacated and set aside Defendant's convictions for murder in the first degree, armed assault with intent to murder, and firearm offenses, holding that four trial errors required that the verdicts be vacated and set aside and this matter remanded to the superior court for a new trial.Specifically, the Supreme Judicial Court held (1) the trial court erred in admitting a coventurer's statements against Defendant under the joint venture exemption to the hearsay rule, and admission of the statements was barred by the Sixth Amendment; (2) the trial court erred in admitting the opinion of the Commonwealth's gang expert, and the error was prejudicial; (3) the trial court erred in allowing police witnesses to give their opinions as to the identity of individuals depicted in surveillance footage; and (4) the prosecutor engaged in impermissible argument during closing, and a new trial was required. View "Commonwealth v. Wardsworth" on Justia Law

The Supreme Judicial Court vacated the order of the superior court denying Boston Globe Media Partners, LLC's (Globe) motion for summary judgment in this public records case, holding that the trial judge erred in concluding that the Department of Public Health (DPH) could withhold requested electronic indices of publicly available birth and marriage data pursuant to Mass. Gen. Laws. ch. 4, 7, twenty-sixth (c) (exemption (c)) but not pursuant to Mass. Gen. Laws ch. 4, 7, twenty-sixth (a) (exemption (a)).The Globe sought the requested records from DPH and asked the trial judge to declare that the indices constituted public records. DPH argued that it could withhold the indices pursuant to exemption (a) or exemption (c). The judge denied the Globe's motion for summary judgment, concluding that the indices could be withheld pursuant to exemption (c). The Supreme Judicial Court remanded the case for further proceedings on both exemptions, holding (1) the Globe's request requires an approach to exemption (a) that takes into account future requests for the indices; and (2) the application of exemption (c) involves a privacy issue that has yet to be addressed in the public records context. View "Boston Globe Media Partners, LLC v. Department of Public Health" on Justia Law

In this case involving Defendant's failure to properly install child safety seats in her vehicle, the Supreme Judicial Court vacated Defendant's convictions of involuntary manslaughter and reckless endangerment as to Dylan Riel but affirmed Defendant's two convictions of negligent homicide, holding that there was insufficient evidence to show that Defendant's conduct was wanton or reckless.Defendant was involved in a multi-vehicle accident in which her two nephews - four-year-old Dylan Riel and and sixteen-month-old Jayce Garcia - were fatally injured. At the time of the accident Dylan was seated in the backseat of Defendant's sedan with a seat belt fastened but without an age and size appropriate child safety booster seat. Jayce was in a front-facing safety seat with the straps set too high rather than an age and size appropriate rear-facing safety seat. Defendant was convicted of manslaughter of Dylan, reckless endangerment of Dylan, and negligent motor vehicle homicide of Dylan and Jayce. The Supreme Court reversed the judgments of conviction of manslaughter and reckless endangerment of a child and otherwise affirmed, holding that there was not legally sufficient evidence to show Defendant's conduct was wanton or reckless. View "Commonwealth v. Hardy" 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, holding that there was no reversible error nor a reason to exercise its authority under Mass. Gen. Laws ch. 278, 33E to either reduce Defendant's convictions or grant a new trial.Specifically, the Court held (1) the trial judge did not err in declining to instruct the jury on voluntary manslaughter; (2) Defendant's age at the time of his crimes - nineteen years old - did not render his sentence of life imprisonment without the possibility of parole unconstitutional; and (3) the trial judge did not clearly err in refusing to grant a new trial due to a partial courtroom closure. View "Commonwealth v. Garcia" on Justia Law

The Supreme Judicial Court reversed the judgment of conviction in this case as to negligent operation and affirmed the judgment of conviction of operating a motor vehicle while under the influence, holding that the evidence was insufficient to support Defendant's conviction of negligent operation.On appeal, Defendant argued, among other things, that the trial judge erred in denying his motion for a required finding of not guilty because the evidence was insufficient to support the convictions. The Appeals Court affirmed Defendant's convictions. The Supreme Judicial Court reversed in part, holding that, under the circumstances of this case, the evidence was insufficient to warrant a finding that Defendant actually operated his vehicle in such a way as to endanger the lives or safety of the public when there was no other evidence of negligent operation. View "Commonwealth v. Zagwyn" on Justia Law

The Supreme Judicial Court affirmed Defendant's sentence of three consecutive terms of life imprisonment, with the possibility of parole after forty-five years, in connection with his conviction of three counts of murder in the first degree, holding that the sentence was within constitutional bounds.Defendant was a juvenile homicide offender and sought resentencing when he was well into adulthood. After the Supreme Judicial Court decided Commonwealth v. Costa, 472 Mass. 139 (2015), the Commonwealth conceded that Defendant was entitled to a resentencing hearing. After a hearing, the sentencing judge reinstated Defendant's sentence. Defendant then filed an application with the Supreme Court pursuant to Mass. Gen. Laws ch. 278, 33E for leave to appeal from the resentencing judge's ruling, as well as a motion for direct entry of the appeal. The single justice directed entry of the appeal on the question of whether a juvenile homicide offender may be required to serve forty-five years in prison before his first opportunity to seek release based on rehabilitation. The Supreme Judicial Court held that Defendant's sentence did not constitute cruel or unusual punishment in violation of article 26 of the Massachusetts Declaration of Rights. View "Commonwealth v. LaPlante" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial judge finding the Massachusetts Water Resources Authority (MWRA) liable for a retaliatory termination and awarding a total damages of $1,332,271, holding that there was no error in the proceedings below.The jury found the MWRA terminated Plaintiff in retaliation for his taking leave under the Family and Medical Leave Act (FMLA), 29 U.S.C. 2615, and expressing his intention to take FMLA leave in the future. The jury awarded back pay damages for Plaintiff's lost wages, made an advisory award of damages for the future loss of Plaintiff's pension benefits, and awarded damages for emotional distress and punitive damages. The trial judge further awarded liquidated damages and attorney's fees and costs. The MWRA appealed, primarily challenging the jury instructions. The Supreme Judicial Court affirmed, holding (1) the trial judge did not commit prejudicial error in instructing the jury; and (2) there was no abuse if discretion in calculating and awarding damages. View "DaPrato v. Massachusetts Water Resources Authority" on Justia Law

The Supreme Judicial Court answered in the affirmative a reported question, holding that a defendant who has pled guilty to possession of a large capacity feeding device in violation of Mass. Gen. Laws ch. 269, 10(m) may lawfully be sentenced to State prison for not less than one year nor more than two and one-half years.Defendant in this case pleaded guilty to possession of a large capacity feeding device and related offenses. Over the Commonwealth's objection, Defendant was sentenced to a term of from one to two and one-half years' imprisonment. The Commonwealth filed a motion for reconsideration, seeking a sentence of at least two and one-half years. The trial judge reported a question to the Appeals Court. The Supreme Judicial Court transferred the case to this Court on its own motion and answered the question as follows: A defendant who was been convicted of possession of a large capacity feeding device lawfully may be sentenced to State prison for not less than one year nor more than two and one-half years. View "Commonwealth v. Rodriguez" on Justia Law