Justia Massachusetts Supreme Court Opinion Summaries

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The Supreme Judicial Court affirmed the judgment of the trial court denying Defendant's motion to suppress drug evidence, holding that the reveal of a plastic bag protruding from the cleft between Defendant's buttocks was within the scope of the lawful strip search and that the actions taken by the police were reasonable.During a lawfully strip search following Defendant's arrest, police officers caused Defendant to move a plastic bag from between his buttocks. The bag was revealed to contain individually wrapped plastic bags of heroin and cocaine. Defendant moved to suppress the drugs found in the plastic bag removed during the strip search. The trial court denied the motion. The Appeals Court reversed, concluding that the police were required under the circumstances to apply for a search warrant to remove the bag because they had failed to ascertain that "no portion of the bag was within Defendant's rectum," which search would require a warrant. The Supreme Judicial Court disagreed, holding that the motion to suppress was properly denied because the Commonwealth met its burden of showing that the protruding plastic bag was not lodged or embedded in Defendant's rectum and that its removal did not cause any manipulation of the rectum. View "Commonwealth v. Jeannis" on Justia Law

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In this case involving involuntary civil commitment due to mental illness, the Supreme Court held that an individual may not be said to have been "discharged" from a facility within the meaning of Mass. Gen. Laws ch. 123 if his iberty has not been restored.D.L. was held involuntarily at Pembroke Hospital on a temporary basis due to mental illness. When Pembroke's petition to extend D.L.'s confinement was denied, Pembroke purportedly "discharged" D.L. but also detained and transported him without his permission to a second hospital for another mental health evaluation. This evaluation led to an order for involuntary confinement. The Appellate Division found that there was no abuse of the involuntary commitment procedure under Mass. Gen. Laws ch. 123, 12. The Supreme Court disagreed, holding that Pembroke violated chapter 123 by failing to discharge D.L. after the denial of its petition to continue D.L.'s confinement. View "Pembroke Hospital v. D.L." on Justia Law

Posted in: Health Law
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In this case involving the issue of how to allocate responsibility for retaining and preserving exhibits after criminal trials the Supreme Judicial Court affirmed the exhibit-transfer orders in two of three criminal cases and affirmed in part and remanded in part the order in the third case, holding that that superior court clerks' offices are responsible for maintaining exhibits post trial unless a clerk's office shows that there is good cause to believe retention would be impracticable.The three postconviction orders at issue in this case, issued by three different superior court judges, required that exhibits in the clerk's office be transferred to local police departments. The district attorney for the northern district petitioned a single justice of the Court seeking to vacate the orders and to require that all exhibits that had been transferred to police departments be returned to the clerk's office. The Supreme Judicial Court held that the clerk's office memorandum in this case was insufficient to satisfy the good cause standard with respect to a baby carriage, but the record supported the judge's decisions with respect to a BB gun, firearms, and ammunition. View "District Attorney for the Northern District v. Superior Court Department" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court affirmed Defendant's conviction of murder in the second degree and affirmed the trial judge's denial of Defendant's motion to reduce the verdict to manslaughter, holding that the trial judge did not err or abuse its discretion in denying Defendant's motion to reduce the motion to reduce the verdict.Defendant filed his motion to reduce the verdict pursuant to Mass. R. Crim. P. 25(b)(2), which authorizes a trial judge to reduce the verdict - even if the evidence warrants the verdict - to help ensure that the result is consonant with justice. The Supreme Judicial Court affirmed the trial judge's denial of the motion, holding that, while the case was a close one, the trial judge did not err or abuse his discretion in deciding not to reduce the verdict. View "Commonwealth v. Grassie" 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 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

Posted in: Criminal Law
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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

Posted in: Criminal Law
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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

Posted in: Juvenile Law
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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

Posted in: Criminal Law
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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

Posted in: Criminal Law
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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