Justia Criminal Law Opinion Summaries

Defendant was convicted of several criminal offenses. Defendant's appeal from his convictions was pending in the appeals court, where he was represented by counsel. Acting pro se, Defendant filed a motion in the appeals court, which responded that it would consider only filings submitted by counsel of record. Defendant filed a petition under Mass. Gen. Laws ch. 211, 3, seeking relief from that ruling and a stay of his appeal until he was allowed to proceed without counsel. A single justice of the Supreme Court denied relief. The Supreme Court affirmed, holding that the court was not obligated to permit Defendant to proceed in a hybrid manner with representation in part by counsel and in part by himself. View "LeBaron v. Commonwealth" on Justia Law

After a jury trial, Defendant was convicted of rape. The appeals court affirmed, concluding that any delay in bringing Defendant to trial did not violate Mass. R. Crim. P. 36. Defendant subsequently filed a motion for a new trial, alleging that appellate counsel was ineffective for failing to argue to the appeals court that Defendant's motion to dismiss on speedy trial grounds should have been allowed under the speedy trial provisions of the state or federal Constitutions. The motion was denied, and the appeals court affirmed. The Supreme Court affirmed, holding Defendant was not denied effective assistance of counsel where (1) the speedy trial clock starts when a Massachusetts criminal complaint issues; (2) the speedy trial clock "resumes" when the Commonwealth reinstates charges following dismissal; and (3) although the delay from the attachment of the right to a speedy trial in September 1991 to Defendant's trial in May 2003 was lengthy, the factors set forth in Baker v. Wingo did not establish that Defendant's constitutional right to a speedy trial was violated. View "Commonwealth v. Butler " on Justia Law

Petitioner was convicted of multiple criminal offenses in 2005. In 2010, Defendant filed a motion for a new trial and an amended motion for a new trial. Neither motion was acted on. Defendant also represented that he filed two additional motions requesting action on his new trial motions but that those motions likewise were unresolved. Defendant filed a petition for relief under Mass. Gen. Laws ch. 211, 3, requesting that a single justice of the Supreme Court grant him a new trial for the reasons stated in the motions he filed in the trial court. The single justice denied the petition. The Supreme Court affirmed, as Petitioner did not (1) demonstrate he had availed himself of all measures available to him in the trial court to obtain a ruling on his motion, (2) provide copies of the motions he stated he filed in the trial court seeking action on his new trial motions, or (3) provide the single justice with a record adequate to support the specific relief he sought. View "Sellers v. Commonwealth" on Justia Law

In the underlying case, a superior court jury convicted Keith Winfield of forcible rape of a child under the age of sixteen, indecent assault and battery of a child under the age of fourteen, and assault and battery of a child causing serious bodily injury. The appeals court affirmed. Steve Audette, a film producer, was making a documentary film about Winfield's prosecution and convictions. After Audette purchased an official transcript of the trial, Audette filed a motion to access an audiotape room recording of the trial made by a court reporter. The motion judge denied the motion. The Supreme Court affirmed, holding (1) where the court reporter's room recording is not the official record of the trial and is not filed with the court or referenced in the court file, Audette was not entitled to a copy under the public's right of access to criminal proceedings guaranteed by the First Amendment or under the State's common-law right of access to judicial records; and (2) the judge did not abuse her discretion in refusing to give Audette access to the recording. View "Commonwealth v. Winfield" on Justia Law

After a jury trial, Defendant was convicted of one count of murder in the first degree and two counts of armed robbery. Defendant did not appeal. Nearly forty-five years later, Defendant filed a motion for a new trial, collaterally attacking his conviction. A judge denied Defendant's amended motion and granted Defendant leave to renew that motion subject to the outcome of his co-defendant's appeal from the denial of a similar motion for new trial. Rather than awaiting the outcome of that case, Defendant appealed the denial of his motion. The Supreme Court subsequently affirmed the denial of the co-defendant's motion for a new trial and concluded that the Court's decision in that case was controlling in the present appeal. The Court affirmed the judge's denial of Defendant's motion for a new trial, holding that the judge's denial of Defendant's motion for new trial was not manifestly unjust, nor was the trial infected with prejudicial constitutional error. View "Commonwealth v. Robideau" on Justia Law

After a jury trial, Defendant and his co-defendant were convicted of felony-murder in the first degree and armed robbery. The Supreme Court (1) affirmed Defendant's conviction of felony-murder in the first degree, holding, among other things, that (i) the evidence was sufficient to support the conviction, (ii) the trial judge erred in admitting evidence of a prior bad act of the co-defendant, but the error was harmless, (iii) the judge did not err in its instructions to the jury, and (iv) Defendant was not entitled to a new trial where the Court concluded that the co-defendant was entitled to a new trial due to errors at trial; and (2) vacated the armed robbery conviction, as it was duplicative of the murder conviction. View "Commonwealth v. Benitez" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree. The Supreme Court affirmed the conviction and the denial of Defendant's motion for a new trial. Defendant later filed a second motion for a new trial, alleging that his counsel was ineffective for failing to raise certain alleged errors at trial and on direct appeal. The superior court denied the motion. The Supreme Court affirmed the order denying the motion for a new trial, holding (1) trial counsel was not constitutionally ineffective in failing to object to two courtroom closures; (2) the trial judge improperly limited the scope of Defendant's cross-examination of a witness for the prosecution, but the error was harmless; (3) Defendant's appellate counsel was not ineffective for failing to cite federal law to support Defendant's claims of error on direct appeal; (4) the trial judge did not err in declining to give a Bowden instruction; and (5) the trial judge properly instructed the jury on consciousness of guilt. View "Commonwealth v. Hardy" on Justia Law

After a jury trial, Defendant was convicted of carrying a firearm without a license based on a theory of constructive possession. Defendant appealed, contending, among other things, that the Commonwealth failed to present sufficient evidence to establish as a matter of law that Defendant had knowledge of the firearm's presence in his vehicle, the ability to exercise control over the weapon, and the intent to do so. The Supreme Court reversed Defendant's conviction and directed that a verdict of not guilty be entered, holding that although the evidence proffered by the Commonwealth was adequate to establish that Defendant knew the firearm was present in the motor vehicle he was operating and that he had the ability to exercise control over the weapon, the evidence was insufficient to prove Defendant had the requisite intention to control the firearm. View "Commonwealth v. Romero" on Justia Law

Defendant was indicted on drug-related charges that included trafficking in cocaine over twenty-eight grams. During the trial, certificates of chemical analysis establishing the weight and identity of the substance alleged to have been in Defendant's possession (drug certificates) were admitted into evidence. Defendant was convicted of the charges. After Defendant appealed, the U.S. Supreme Court issued its decision in Melendez-Diaz v. Massachusetts, which held that a drug analyst's certificate is testimonial and cannot be admitted at trial unless a defendant has the opportunity to cross-examine the analyst. Defendant then filed a motion for a new trial, arguing that the admission of the drug certificates violated his right to confrontation. The judge denied the motion, concluding that admission of the drug certificates was harmless beyond a reasonable doubt. The Supreme Court vacated Defendant's convictions and remanded the case for a new trial, holding that the erroneous admission of the drug certificates was not harmless beyond a reasonable doubt. View "Commonwealth v. Montoya" on Justia Law

Defendant was convicted of the deliberately premeditated murder of his wife. The Massachusetts Supreme Court affirmed, but the U.S. Supreme Court vacated the judgment and remanded the case in light of the recent U.S. Supreme Court decision in Williams v. Illinois, which addressed the admissibility under the Confrontation Clause of expert testimony about the results of DNA testing performed by non-testifying analysts. On remand, the Court reconsidered of the admissibility of testimony of an expert witness regarding DNA testing where the witness did not prepare the underlying data. The Supreme Court affirmed, holding (1) the Court's rules of evidence and the protections they afford are not inconsistent with Williams; (2) the witness's expert opinion that Defendant's DNA matched the DNA on items recovered from the crime scene was properly admitted; and (3) the witness's direct testimony to the details of the DNA test results of a nontestifying analyst was improperly admitted, but Defendant was not prejudiced by the erroneous admission. View "Commonwealth v. Greineder" on Justia Law