Justia Criminal Law Opinion Summaries

The Supreme Judicial Court affirmed Defendant's conviction of two counts of aggravated assault and one count of assault a child younger than six years old, holding that there was no prosecutorial misconduct, the trial court's jury instructions did not constitute obvious error, and there was sufficient evidence in the record to support the jury's verdict.Specifically, the Court held (1) the State did not engage in prosecutorial misconduct during the trial; (2) there was no obvious error in the trial court's instructions to the jury on the elements of the aggravated assault charges; and (3) the evidence was insufficient to support the conviction for one of the aggravated assault charges. View "State v. Coleman" on Justia Law

The Supreme Judicial Court affirmed Defendant's judgment of conviction of manslaughter following a jury trial on an indictment for murder, holding that the trial court did not clearly err or abuse its discretion in the proceedings below.Specifically, the Court held that the trial court (1) acted within its discretion in its conduct of voir dire, which addressed virtually all of Defendant's concerns; (2) did not clearly err in admitting a photograph of the victim with his son and acted within its discretion in overruling Defendant's Rule 403 objection; and (3) did not abuse its discretion by giving a curative instruction after the prosecutor misstated the evidence during closing arguments because the curative instruction adequately remedied any prejudice to Defendant. View "State v. Bethea" on Justia Law

The Supreme Judicial Court vacated the judgment of the trial court convicting Defendant of operating under the influence, operating after suspension, and criminal speeding, holding that the court's instructions contained obvious error by informing the jury that it could consider evidence of a failure to submit to a test on the issue of operation.On appeal, Defendant argued that he did not receive a fair trial because the jury was instructed about how it could properly consider evidence of his failure to submit to a breath or blood alcohol test. The Supreme Court agreed and remanded the case for a new trial, holding (1) because the jury instructions misstated the law and remained incorrect by any other component of the jury charge the instructions constituted plain error; and (2) the error rose to the level of obvious error because there was a reasonable probability that it affected the outcome of the trial and Defendant's substantial rights. View "State v. Thurlow" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder entered by the trial court after a jury-waived trial, holding that that the court did not err in admitting certain testimony given by the mother of the victim and that the sentence was without error.Specifically, the Court held (1) the trial court erred in admitting the mother's hearsay testimony, but the error was harmless because it was highly probable that the error did not affect the factfinder's judgment; and (2) the court did not "double-count" the factor of domestic violence in reaching its sentence. View "State v. Sweeney" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of two counts of intentional or knowing murder, holding that the trial court did not err in denying Defendant's motion to suppress evidence of his cell site location information (CSLI).On appeal, Defendant argued that the judge who issued the warrant permitting officers to obtain his CLSI erred in determining that there was probable cause supporting the warrant's issuance. The Supreme Judicial Court affirmed the denial of Defendant's motion to suppress evidence of his CSLI, holding that the information in the affidavit was sufficient to support the judge's determination that there was probable cause to believe that Defendant was involved in the two homicides and that his CSLI would contain or constitute evidence relevant to the crime. View "State v. Marble" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of operating a vehicle when the registration of that vehicle was suspended, holding that the State was not required to provide counsel to Defendant.Defendant was tried before a jury without counsel. The jury returned a verdict of guilty, and the trial court entered a judgment after imposing a fine supplemented by surcharges. Defendant appealed, arguing that he had a right to court-appointed counsel because of his inability or unwillingness to pay a fine and that jury selection proceedings were deficient. The Supreme Judicial Court affirmed, holding (1) because Defendant was not at risk of incarceration as part of the sentence the State was not required to provide counsel; and (2) there was no basis for a claim of legal error or abuse of discretion regarding jury proceedings. View "State v. Lipski" on Justia Law

The Supreme Judicial Court affirmed the judgment of conviction of burglary entered by the trial court after a jury trial, holding that the trial court did not err in admitting recordings of incriminating telephone conversations that Defendant had with his girlfriend while he was in jail.A jury found Defendant guilty of burglary. The court sentenced Defendant to one year in prison, with all but sixty days suspended, and a one-year term of probation. On appeal, Defendant primarily challenged the adequacy of the foundation that the State provided to establish the authenticity of the jail recordings. The Supreme Judicial Court affirmed, holding that there was no evidence of tampering and that the court did not err in finding a sufficient foundation for the recordings' admissibility. View "State v. Coston" on Justia Law

The Supreme Judicial Court vacated in part the order of the superior court granting Defendant's motion to suppress evidence obtained pursuant to a search warrant for Defendant's cell phone account data and a search warrant for a codefendant's cell phone data, holding that there was no illegality in the search of Defendant's data and that Defendant lacked standing to challenge the search of the codefendant's data.On appeal, the State argued that Defendant lacked standing to challenge the warrant issued to search the codefendant's account data and that the superior court erred by determining that neither search warrant was supported by probable cause. The Supreme Judicial Court vacated the order to the extent that it suppressed the evidence obtained through the two warrants, holding (1) the affidavit for the warrant to search Defendant's account data was supported by probable cause; and (2) given that Defendant failed to assert any reasonable expectation of privacy in the codefendant's account data, Defendant lacked standing to challenge the warrant to search the codefendant's data. View "State v. Warner" on Justia Law

The Supreme Judicial Court vacated the judgment entered by the trial court convicting Defendant of unlawful sexual touching and assault, holding that the court erred in allowing the State to introduce improper character evidence and that the prejudice suffered as a result of that error, when considered cumulatively with the effect of an instance of prosecutorial misconduct, deprived Defendant of a fair trial.Although the issue was not preserved at trial or raised on appeal, the Supreme Judicial Court examined the State's cross-examination of Defendant to determine whether prosecutorial misconduct occurred. The Supreme Judicial Court remanded the case for a new trial, holding (1) on the record, prosecutorial misconduct plainly occurred, and the misconduct affected Defendant's substantial rights; (2) the introduction into evidence of federal probation violations was error and highly prejudicial to Defendant; and (3) the cumulative effect of the trial errors deprived Defendant of a fair trial. View "State v. Robbins" on Justia Law

The Supreme Judicial Court affirmed the judgment of the unified criminal docket convicting Defendant of unlawful sexual contact, holding that the trial court did not err when it admitted in evidence as past recollection recorded a video recording in which the victim described Defendant's assaults of her.The video recording was of a forensic interview conducted of the victim shortly after the crime occurred. On appeal, Defendant argued that the court erred in admitting the video in evidence because the State had not established the proper foundation required by the exception to the hearsay rule and because the admission of the video violated his constitutional right to confront the witness. The Supreme Judicial Court disagreed, holding (1) the court did not err by determining that the State had satisfied the foundational elements of the recorded recollection exception to the hearsay rule; and (2) the court did not violate Defendant's constitutional right to confrontation by admitting the evidence because Defendant was provided the opportunity to cross-examine the victim about her out-of-court statements. View "State v. Adams" on Justia Law