Justia Criminal Law Opinion Summaries

After a jury trial, Defendant was convicted of manslaughter. The principal question on appeal was whether, during a trial where the defendant raises a claim of self-defense and, pursuant to Commonwealth v. Adjutant, has been permitted to introduce evidence of the victim's prior violent acts on the issue of the identity of the first aggressor, the Commonwealth may introduce evidence of the defendant's prior violent acts on that same issue, to be followed by an instruction that the jury may consider the evidence of both parties' violent acts on the findings of who was the first aggressor. The Supreme Court answered yes, provided that the Commonwealth gives the defendant notice appropriately in advance of its intent to introduce such evidence and the trial judge determines that introduction of such evidence is more probative of its intended purpose than prejudicial to the defendant. In so answering, the Court affirmed the judgment of the trial court. View "Commonwealth v. Morales" on Justia Law

In 2010, a criminal complaint was filed in the district court charging Defendant with the commission of an armed robbery that took place in 2000. More than ten years after the date of the armed robbery, a grand jury returned an indictment against Defendant for that offense. The superior court dismissed the case with prejudice, concluding that the statute of limitations required an indictment to be issued and filed within ten years from the date of the offense. The Supreme Court affirmed, holding (1) the relevant statute requires the filing of an indictment within the ten-year limitations period for armed robbery; and (2) the filing of a complaint within the limitations period, and the return of an indictment outside of that period, does not constitute timely commencement of the criminal proceeding. View "Commonwealth v. Perella" on Justia Law

In 1995, Defendant was charged with assault and battery by means of a dangerous weapon and indecent assault and battery on a child under the age of fourteen. At the time, Defendant was a minor and primarily spoke Khmai. During his plea colloquy, Defendant admitted to sufficient facts and was placed on probation. Defendant was committed to the Department of Youth Services after he violated the terms of his probation. In 2009, as an adult, Defendant sought to vacate his pleas, asserting he did not knowingly and voluntarily admit to sufficient facts where no interpreter was present during his plea colloquy and where he was denied effective assistance of counsel. The juvenile court denied Defendant's motion for a new trial, and the appeals court affirmed. The Supreme Court affirmed, holding that Defendant did not provide sufficient evidence to rebut the presumption of regularity of his plea proceedings and did not demonstrate he was denied the effective assistance of counsel. View "Commonwealth v. Yardley Y." on Justia Law

Defendant had a license permitting him to carry a firearm for all lawful purposes. After driving to work one day, Defendant attempted to obtain a gun locker key for the storage of his firearm during his work shift, but all the lockers were full. Consequently, Defendant placed his gun in his vehicle's glove box and locked the vehicle. Defendant's car was later searched, and Defendant was charged with firearms violations. After a jury trial, Defendant was convicted of improperly carrying a firearm in a motor vehicle in violation of the carrying statute and unlawfully storing a firearm in violation of the storage statute. The Supreme Court reversed, holding (1) the evidence was insufficient to support Defendant's conviction under the carrying statute, and Defendant was entitled to a directed verdict of not guilty on that charge; and (2) because the trial judge did not properly instruct the jury regarding what qualifies as a locked container, Defendant's conviction under the storage statute was reversed and the case remanded for a new trial on that charge. View "Commonwealth v. Reyes" on Justia Law

Defendant had a valid license to carry a firearm in Massachusetts. Defendant owned a semiautomatic handgun, which he kept loaded and unlocked in a bedroom drawer in his home. Defendant was charged with violating Mass. Gen. Laws ch. 149, 131L(a), which makes it unlawful to store a firearm not under the immediate control of the authorized user unless the firearm is secured in a locked container or equipped with a safety device that renders the firearm inoperable by anyone other than the authorized user. Defendant moved to dismiss the complaint, alleging that the statute was unconstitutional. The Supreme Court held (1) section 131L(a) is subject only to a rational basis analysis; (2) the statute is constitutional under the U.S. Supreme Court's holding in District of Columbia v. Heller and McDonald v. Chicago; and (3) Massachusetts may enforce section 131L(a) to protect the health, safety, and welfare of its citizens. View "Commonwealth v. McGowan" on Justia Law

Defendant was charged initially by complaint with murder. After Defendant was arraigned, the judge scheduled a probable cause hearing. However, due to several continuances requested by the prosecutor, the probable cause hearing was not held before the grand jury returned an indictment charging Defendant with murder in the first degree. Before the indictment was returned, Defendant filed a petition seeking an order that a probable cause hearing be conducted. A single justice denied the requested relief. The Supreme Court dismissed Defendant's appeal as moot, holding (1) Mass. Gen. Laws ch. 276, 38 is applicable to a defendant who is initially charged by complaint with murder in the first degree and provides the defendant with the right to a probable cause hearing as soon as practicable in the circumstances; (2) the Commonwealth need not conduct the probable cause hearing within a definite time frame, but the Commonwealth must demonstrate good cause to justify any request by the Commonwealth to continue it; and (3) in the instant case, the single justice did not abuse his discretion in denying the relief sought by Defendant. View "Commonwealth v. Perkins" on Justia Law

After a jury trial, Defendant and a codefendant were each convicted of assault and battery. Defendant subsequently filed a motion for a new trial, alleging ineffective assistance of counsel. After a hearing, the court denied the motion, finding that counsel's performance did not prejudice Defendant. The Supreme Court affirmed the conviction and the order denying Defendant's motion for a new trial, holding that the district court did not err in (1) denying Defendant's motion for a required finding of not guilty; (2) denying Defendant's motion to dismiss based on the loss of exculpatory evidence; (3) instructing the jury on multiple defendants; and (4) denying Defendant's motion for a new trial. View "Commonwealth v. Marinho" on Justia Law

In 2003, Defendant was convicted of murder in the second degree. The conviction was affirmed on direct appeal. In 2007, in light of a decision by a Federal court, Defendant moved for a new trial, arguing that his right to a public trial was violated when court officers excluded his family from the courtroom during jury selection and his counsel failed to object. After a hearing, the judge determined (1) the exclusion of Defendant's family constituted structural error but that there was no miscarriage of justice because closing the court did not materially impact the case or verdict; and (2) defense counsel's failure to object to the closure was a reasonable tactical decision. The Supreme Court affirmed the order denying Defendant's motion for a new trial, holding that the judge did not err in finding that defense counsel's tactical decision not to object to the courtroom closure was not manifestly unreasonable when made, and thus, Defendant was not deprived of effective assistance of counsel. View "Commonwealth v. Lavoie" on Justia Law

Following a joint trial, a jury found Defendants, Terrence Brown and Nathan Rivera, guilty of murder in the first degree, armed assault in a dwelling, home invasion, and unlawful possession of a firearm. Rivera was additionally found guilty of armed assault with intent to murder. On appeal, both Defendants principally argued the admission of a statement Brown made to police was prejudicial error. The Supreme Court affirmed, holding (1) Brown's statement to police admitting his involvement in the home invasion was not obtained in violation of the Massachusetts Declaration of Rights and Commonwealth v. Mavredakis; and (2) the trial judge did not abuse his discretion by admitting a redacted version of Brown's statement and denying Rivera's motions to sever the trials on this basis; and (3) the admission of Brown's redacted statement did not violate Brown's right to a fair trial by impairing his ability to present a defense of withdrawal. View "Commonwealth v. Rivera" on Justia Law

Defendant was charged with home invasion and other offenses. Defendant filed a motion to suppress an audio recording allegedly made by a key witness in violation of state and federal wiretap laws. The witness was receiving witness protection services from the Commonwealth. Defendant then moved for issuance of a summons to secure the witness's attendance at the suppression hearing. A superior court judge ordered that the Commonwealth file the witness's address with the court under seal so that a summons could be served in time for the suppression hearing. The Commonwealth sought relief from this order. The Supreme Court affirmed, holding that, under these circumstances, the judge was within his discretion to order this limited disclosure. View "Commonwealth v. Platt" on Justia Law