Justia Criminal Law Opinion Summaries

The Supreme Court affirmed in part and reversed in part the judgment of the trial court convicting Defendant of incest, first-degree unlawful transaction with a minor, use of a minor in a sexual performance, first-degree unlawful imprisonment, and first-degree sexual abuse. The trial court sentenced Defendant to seventy years’ imprisonment. In reversing in part, the Supreme Court held that Defendant’s convictions of incest, use of a minor in a sexual performance, and unlawful imprisonment were reasonably likely a result of prosecutorial vindictiveness. The court otherwise affirmed, holding that the trial court (1) did not err in overruling Defendant’s motion to dismiss his indictment due to prosecutorial vindictiveness; (2) did not err by not granting a directed verdict on the charge of unlawful transaction with a minor; (3) did not permit double jeopardy violations; and (4) erred by permitting the victim’s mother to improperly vouch for the victim’s credibility, but the error was harmless. View "Yates v. Commonwealth" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Appellant of murder, criminal attempt to commit murder, and related crimes. The Supreme Court held that the trial court (1) did not err by denying Appellant’s request to introduce parole eligibility information during the death penalty phase of the trial; (2) did not err by permitting the Commonwealth to introduce during the guilt phase evidence of other crimes committed by Appellant against the victim’s family; and (3) did not err by allowing the testimony of a witness who was three years old at the time of the crimes and six years old at the time of the trial. View "Huddleston v. Commonwealth" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Appellant of murder, criminal attempt to commit murder, and related crimes. The Supreme Court held that the trial court (1) did not err by denying Appellant’s request to introduce parole eligibility information during the death penalty phase of the trial; (2) did not err by permitting the Commonwealth to introduce during the guilt phase evidence of other crimes committed by Appellant against the victim’s family; and (3) did not err by allowing the testimony of a witness who was three years old at the time of the crimes and six years old at the time of the trial. View "Huddleston v. Commonwealth" on Justia Law

The Supreme Court affirmed the district court’s denial of Defendant’s motion to suppress the evidence obtained during a traffic stop, holding that the law enforcement officer did not violate Defendant’s right to privacy when he reviewed Defendant’s license and registration information.The officer’s police car in this case was equipped with a camera that could read license plates in order to provide information about the vehicle’s registered owner. The record check performed by the camera indicated that Defendant had an active warrant for failing to appear in court. The officer pulled Defendant’s vehicle over and, after noticing several signs that Defendant was intoxicated, arrested Defendant for, inter alia, driving under the influence. The district court denied Defendant’s motion to suppress, and the court of appeals affirmed. The Supreme Court affirmed, holding (1) Defendant’s rights under the Fourth Amendment were not violated by the officer obtaining information linked to Defendant’s license plate, which was displayed in a place where Defendant had no reasonable expectation of privacy; and (2) the officer had the articulable and reasonable suspicion required to stop the vehicle. View "Traft v. Commonwealth" on Justia Law

The Supreme Court affirmed the district court’s denial of Defendant’s motion to suppress the evidence obtained during a traffic stop, holding that the law enforcement officer did not violate Defendant’s right to privacy when he reviewed Defendant’s license and registration information.The officer’s police car in this case was equipped with a camera that could read license plates in order to provide information about the vehicle’s registered owner. The record check performed by the camera indicated that Defendant had an active warrant for failing to appear in court. The officer pulled Defendant’s vehicle over and, after noticing several signs that Defendant was intoxicated, arrested Defendant for, inter alia, driving under the influence. The district court denied Defendant’s motion to suppress, and the court of appeals affirmed. The Supreme Court affirmed, holding (1) Defendant’s rights under the Fourth Amendment were not violated by the officer obtaining information linked to Defendant’s license plate, which was displayed in a place where Defendant had no reasonable expectation of privacy; and (2) the officer had the articulable and reasonable suspicion required to stop the vehicle. View "Traft v. Commonwealth" on Justia Law

The Supreme Court affirmed the judgment of the circuit court sentencing Defendant to life imprisonment for murder, first-degree assault, and other crimes and sentencing Defendant to life imprisonment for murder. The court held (1) the trial court did not abuse its discretion in denying Defendant’s motion for change of venue; (2) the trial court did not abuse its discretion in denying Defendant’s motion to exclude an incriminating statement Defendant made to a witness; (3) the trial court did not abuse its discretion in denying Defendant’s motions for a continuance; (4) the trial court did not abuse its discretion by refusing Defendant’s motion to excuse jurors for cause; (5) the trial court did not abuse its discretion in denying Defendant’s request for a mistrial; and (6) the trial court erred in permitting testimony about what would constitute an appropriate sentence for Defendant, but the error was harmless. View "Hilton v. Commonwealth" on Justia Law

The Supreme Court affirmed the judgment of the circuit court sentencing Defendant to life imprisonment for murder, first-degree assault, and other crimes and sentencing Defendant to life imprisonment for murder. The court held (1) the trial court did not abuse its discretion in denying Defendant’s motion for change of venue; (2) the trial court did not abuse its discretion in denying Defendant’s motion to exclude an incriminating statement Defendant made to a witness; (3) the trial court did not abuse its discretion in denying Defendant’s motions for a continuance; (4) the trial court did not abuse its discretion by refusing Defendant’s motion to excuse jurors for cause; (5) the trial court did not abuse its discretion in denying Defendant’s request for a mistrial; and (6) the trial court erred in permitting testimony about what would constitute an appropriate sentence for Defendant, but the error was harmless. View "Hilton v. Commonwealth" on Justia Law

The Supreme Court affirmed the circuit court order, entered after a hearing, summoning William Joseph Wilkie to appear and testify in an out-of-state criminal proceeding in Clay County, Minnesota but reversed and remanded the order summoning Wilkie’s granddaughter, M.M.W., to appear and testify in the same criminal proceeding.In this consolidated appeal, Wilkie and M.M.W. argued that their rights as victims in the criminal proceeding were violated because they were not advised of their right to counsel during the circuit court hearing. The Supreme Court affirmed in part and reversed and remanded in part holding (1) because the proceedings in South Dakota did not implicate S.D. Const. art. VI, section 29, the circuit court had no obligation to advise either Wilkie or M.M.W. of any rights under Marsy’s Law; but (2) while the circuit court did not err in finding that Wilkie failed to present any evidence of hardship for himself in ordering Wilkie to appear and testify in Minnesota, the circuit court failed to make adequate findings on M.M.W.’s claim of hardship. View "In re Issuance of a Summons Compelling an Essential Witness to Appear & Testify" on Justia Law

The Supreme Court affirmed the circuit court order, entered after a hearing, summoning William Joseph Wilkie to appear and testify in an out-of-state criminal proceeding in Clay County, Minnesota but reversed and remanded the order summoning Wilkie’s granddaughter, M.M.W., to appear and testify in the same criminal proceeding.In this consolidated appeal, Wilkie and M.M.W. argued that their rights as victims in the criminal proceeding were violated because they were not advised of their right to counsel during the circuit court hearing. The Supreme Court affirmed in part and reversed and remanded in part holding (1) because the proceedings in South Dakota did not implicate S.D. Const. art. VI, section 29, the circuit court had no obligation to advise either Wilkie or M.M.W. of any rights under Marsy’s Law; but (2) while the circuit court did not err in finding that Wilkie failed to present any evidence of hardship for himself in ordering Wilkie to appear and testify in Minnesota, the circuit court failed to make adequate findings on M.M.W.’s claim of hardship. View "In re Issuance of a Summons Compelling an Essential Witness to Appear & Testify" on Justia Law

The Supreme Judicial Court declined, in this case, to depart from the tenet that a traffic stop constitutes a reasonable seizure for purposes of article 14 of the Massachusetts Declaration of Rights where a police officer has observed a traffic violation, notwithstanding the officer’s underlying motive for conducting the stop.The Supreme Judicial Court affirmed the denial of Defendant’s motion to suppress evidence seized during a traffic stop and affirmed Defendant’s conviction of unlawful possession of a controlled substance, holding (1) the stop at issue was justified based on the law enforcement officer’s observation of the vehicle speeding; (2) a question to the driver about the smell of marijuana did not fall beyond the permissible scope of the stop; and (3) the motion judge did not err in finding that the driver freely and voluntarily consented to the search of the vehicle. View "Commonwealth v. Buckley" on Justia Law