Justia Criminal Law Opinion Summaries

Plaintiff, an inmate at a correctional center, was held in administrative segregation in center's special management unit (SMU) on awaiting action status as prison officials sought his transfer or reclassification. During that time, Plaintiff's detainment was given the informal review provided by the Department of Correction (DOC) regulations that govern detention of inmates in an SMU. Claiming that he was entitled the review procedures provided by regulation to inmates housed in a departmental segregation unit, Plaintiff brought suit alleging violations of his constitutional due process rights and of various state statutes and regulations, and seeking declaratory and injunctive relief as well as money damages. The superior court granted Plaintiff's partial motion for summary judgment, ruling that Defendants had violated his right to due process. The judge denied Defendants' cross motion for summary judgment insofar as it sought to dismiss Plaintiff's claims as barred under the doctrine of qualified immunity for public officials. The Supreme Court held (1) Plaintiff's administrative segregation was unlawful, but (2) the law in this regard was not clearly established at the time of the underlying events, and with respect to Plaintiff's claim for damages, Defendants were entitled to summary judgment on the basis of qualified immunity. View "LaChance v. Comm'r of Corr." on Justia Law

Defendant was indicted for possession with intent to distribute heroin and for possession with intent to distribute heroin, subsequent offense. The charges resulted from the execution of a search warrant at Defendant's home. The affidavit submitted in support of the search warrant application stated that the police had conducted four controlled drug purchases from Defendant and referred to five different confidential informants. Defendant filed a motion for disclosure of the identity of one of the informants, stating she believed the informant was John Smith and that she intended to raise an entrapment defense at trial. The judge who acted on the motion ordered that the Commonwealth confirm or deny whether the informant was Smith. The Commonwealth filed a petition seeking relief from the order, which a single justice denied. The Supreme Court affirmed and ordered the Commonwealth to comply with the order forthwith. View "Commonwealth v. Elias" on Justia Law

Defendant was classified by the sex offender registry board as a level two sex offender. Defendant subsequently registered with the police department. When Defendant failed to register again a few months later during the month of his birth, he was charged with a single count of failing to register as a sex offender in violation of Mass. Gen. Laws ch. 6, 178F 1/2. Defendant pled guilty to the offense and later filed a motion to withdraw the guilty plea. His motion was denied. The Supreme Court reversed, holding (1) although Defendant admitted during the plea hearing that he did not register in his birth month, the statute did not require him to do so; and (2) being under no obligation to register in his birth month, Defendant could not be convicted of the offense of failure to register. View "Commonwealth v. Loring" on Justia Law

A superior court jury convicted Defendant of murder in the first degree on a theory of deliberate premeditation, and of two firearms offenses. On appeal, Defendant claimed error in a number of respects. The Supreme Court reversed Defendant's convictions, set the verdicts aside, and remanded for a new trial, holding (1) it was clear error to preclude Defendant's use of an unavailable witness's grand jury testimony, as requested, for impeachment purposes, and the error was not harmless beyond a reasonable doubt; (2) the admission of certain photographs into evidence was prejudicial error; and (3) the introduction of a rap video as evidence of Defendant's gang membership was prejudicial error. View "Commonwealth v. Gray" on Justia Law

Based on an informant's tip, as well as police observation of three controlled drug purchases and additional surveillance, police obtained a warrant to search Defendant's apartment. They found a firearm and significant quantities of heroin and cocaine. On this basis, Defendant was charged with various drug and firearm offenses. Defendant moved to suppress the contraband as the fruit of an unlawful search of her apartment. Defendant appealed, claiming in relevant part that the affidavit supporting the search warrant was insufficient to establish probable cause to believe that drugs would be found in her residence because the information in the affidavit did not prove an adequate "nexus" between her drug sales and her residence. A superior court judge agreed and allowed the motion to suppress. The Supreme Court reversed the order allowing Defendant's motion to suppress the contraband, holding that the affidavit supporting the search warrant established a sufficient nexus to Defendant's apartment to support a finding of probable cause that contraband related to drug sales would be found in the location searched. View "Commonwealth v. Tapia" on Justia Law

Defendant was convicted by a jury of murder in the first degree on a theory of deliberate premeditation in the stabbing death of her boyfriend. Defendant appealed from both her conviction and the denial of her motion for a new trial. The Supreme Court reversed Defendant's conviction and remanded the matter for a new trial because (1) on multiple occasions, over objection, the trial judge erroneously allowed the Commonwealth to introduce highly prejudicial evidence of Defendant's prior bad acts; and (2) the judge later declined to provide an instruction as to the excessive use of force in self-defense that was supported by the evidence. View "Commonwealth v. Anestal" on Justia Law

Defendant filed a petition seeking reversal of an order of the superior court that denied Defendant's motion to correct his jail time credit to include fourteen days spent in custody awaiting trial on charges pertaining to various property crimes. The motion was filed nearly five years after Defendant had completed his sentence on an unrelated rape conviction and sought to apply the fourteen days of credit to that sentence. The receipt of such credit would have had the effect of granting Defendant an earlier release date on the rape conviction. As a consequence, Defendant no longer would have been a lawful "prisoner" at the time the Commonwealth filed a petition for his civil commitment as a sexually dangerous person and, therefore, would not have been subject to such a commitment. The superior court concluded that Defendant's motion was untimely and moot. A single justice denied his petition for extraordinary relief. The Supreme Court affirmed, holding that Defendant's claim for jail time credit should have been raised while he still was serving his sentence on the rape conviction when, if appropriate, relief could have been afforded. View "Williams v. Superintendent, Mass. Treatment Ctr." on Justia Law

At issue in this case was whether the crime of leaving the scene of an accident where death resulted requires the Commonwealth to prove that the defendant knew he collided with a person. Because the superior court judge initially agreed with the Commonwealth that it had no such burden, he found Defendant guilty. However, the judge allowed Defendant's motion for relief from judgment on the ground that the Commonwealth did have such a burden of proof, and ordered a judgment of acquittal to be entered. The Commonwealth appealed. The Supreme Court affirmed, holding that under Mass. Gen. Laws ch. 90, 24(2)(a 1/2)(2), the Commonwealth must prove the defendant knew he collided with or otherwise caused injury to a person. View "Commonwealth v. Daley" on Justia Law

After a jury trial, Defendant was convicted of unlawful possession of a firearm and unlawful possession of a loaded firearm. In addition, Defendant was convicted after a jury-waived trial of violating the armed career criminal statute. The only ammunition in evidence was that which was loaded in the firearm. The appeals court (1) reversed the convictions on the ground that certificates of ballistics analysis were admitted in violation of Defendant's constitutional right to confront witnesses against him; and (2) directed the entry of judgment for Defendant on the loaded firearm charge on the ground that, where he had been acquitted of possessing the ammunition that was loaded into the firearm, retrial on that charge would violate double jeopardy protections and principles of issue preclusion. The Supreme Court reversed in part, holding that Defendant's acquittal on the ammunition charge did not preclude retrial on the loaded firearm charge. View "Commonwealth v. Charles" on Justia Law

After a mistrial at which the jury was deadlocked, Defendant was retried and convicted of two indictments charging murder in the first degree on a theory of deliberate premeditation. The Supreme Court affirmed the convictions, holding (1) the trial court properly disallowed Defendant's claims that his motion to dismiss the indictments, filed before retrial, because the Commonwealth presented legally sufficient evidence at his first trial; (2) a second trial in these circumstances did not violate constitutional and common-law prohibitions against double jeopardy; (3) the trial judge did not err in his evidentiary rulings or in failing to instruct the jury pursuant to Commonwealth v. Bowden. View "Commonwealth v. Fitzpatrick" on Justia Law