Justia Criminal Law Opinion Summaries

After a jury trial, Defendant was found guilty of deliberately premeditated murder in the first degree and sentenced to life imprisonment without the possibility of parole. Defendant was sixteen years old at the time of the murder. Defendant appealed, raising several allegations of error. The Supreme Court (1) affirmed Defendant’s convictions, holding that the motion judges and trial judge did not commit reversible error or abuse their discretion in their rulings and that Defendant’s counsel did not provide ineffective assistance; but (2) remanded the case to the superior court for resentencing, holding that, pursuant to the Court’s decision in Diatchenko v. Dist. Attorney interpreting the U.S. Supreme Court’s decision in Miller v. Alabama, Defendant was eligible for parole in accordance with the terms of Mass. Gen. Laws ch. 127, 133A. View "Commonwealth v. Ray" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree. During jury empanelment, the court room was closed to all members of the public, including Defendant’s family. After the Supreme Court’s ruling in Commonwealth v. Cohen, which held that the right to a public trial extended to jury empanelment, Defendant filed a motion for a new trial, asserting that the closure of the court room during his trial was structural error requiring reversal. The motion judge denied the motion, concluding that the seventy-nine minute closure was de minimis. The Supreme Court affirmed on other grounds, holding (1) the closure of a court room for the entire empanelment process is not de minimis, but Defendant waived his right to a public trial where his counsel was aware of the closure and did not object; and (2) counsel’s failure to object did not constitute ineffective assistance of counsel. View "Commonwealth v. Morganti" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on theories of deliberate premeditation and felony-murder. The Supreme Court affirmed Defendant’s convictions, holding (1) the motion judge correctly denied Defendant’s motions for a new trial based on Defendant’s assertions that newly discovered evidence called into question the trial testimony of two of the Commonwealth’s witnesses, and the motion judge did not abuse her discretion in denying Defendant’s requests for posttrial discovery; and (2) the trial judge did not commit prejudicial error in failing to give a specific instruction on witness credibility and in making certain evidentiary rulings. View "Commonwealth v. McGee" on Justia Law

In 2004, after a jury trial, Defendant was convicted of murder in the second degree. During jury empanelment, the court officers closed the court room to all members of the public, including Defendant’s family and friend. In 2008, after Defendant unsuccessfully filed a motion for a new trial and unsuccessfully appealed, Defendant filed a second motion for new trial, claiming that the closure of the court room was structural error requiring reversal. On remand, the motion judge denied the motion, concluding that the brief closure of the court room for jury empanelment was de minimis. The Supreme Court affirmed the denial of Defendant’s motion for new trial but on other grounds, holding (1) although the closure of the court room for the entire empanelment process was not de minimis, Defendant waived his right to a public trial where his experienced trial counsel was aware that the court room was routinely closed to spectators during the jury empanelment process and did not object; and (2) counsel’s failure to object did not deprive Defendant of the effective assistance of counsel. View "Commonwealth v. Alebord" on Justia Law

After a jury trial, George Labadie and Susan Carcieri, the latter of whom was employed by a federal credit union, were convicted of violating Mass. Gen. Laws. ch. 266, 52 for embezzling a “bank.” At issue on appeal was whether an employee of a federal credit union may be found guilty under section 52 of embezzlement of the credit union’s funds. The Supreme Court reversed and vacated Defendants’ convictions, holding (1) because the Commonwealth must prove under section 52 that the victim was a “bank” and because a federal credit union is not a “bank” as defined in Mass. Gen. Laws ch. 167, 1, Defendants were entitled to judgments of acquittal on this charge; (2) larceny by embezzlement is a lesser included offense of embezzlement of a bank, and federal preemption doctrine does not bar state prosecution of a federal credit union employee for larceny by embezzlement; and (3) the jury’s verdicts demonstrated that the jurors found Defendants guilty of the required elements of the lesser included offense of larceny by embezzlement. Remanded for entry of convictions of larceny by embezzlement. View "Commonwealth v. Labadie" on Justia Law

After a jury trial, Defendant was convicted of murder and related firearm charges. The appeals court affirmed. Defendant appealed, arguing that the trial court erred in denying his motion to suppress statements he made to the police during an interview at the police station. The Supreme Court affirmed, holding that the trial court did not err in admitting the statements where (1) because Defendant’s claimed invocations of the right to counsel were made before the interrogation became custodial, Defendant did not effectively invoke that right; (2) the totality of the circumstances supported the conclusion that Defendant’s statements were voluntary; and (3) even if Defendant did not validly waive his Miranda rights before making statements during the custodial portion of the interview, the admission of those statements was harmless beyond a reasonable doubt. View "Commonwealth v. Molina" on Justia Law

After a jury trial, Defendant, who was a juvenile at the time of the offense for which he was found guilty, was convicted of murder in the first degree for his knowing participation along with three other young men in the killing of the victim. The Supreme Court (1) affirmed Defendant’s conviction, holding (i) Defendant’s trial counsel did not render constitutionally deficient assistance by failing to obtain a full transcript of a witness’s testimony from another trial for impeachment purposes, (ii) the admission of state of mind evidence did not prejudice Defendant under the circumstances, and (iii) the prosecutor’s inconsistent closing argument at another trial related to the killing and Defendant’s trial did not prejudice Defendant; and (2) vacated Defendant’s sentence and remanded for resentencing, holding that Defendant’s sentence of life in prison without parole was invalid under the Eighth Amendment. View "Commonwealth v. Keo" on Justia Law

Defendant was convicted of two indictments alleging receipt of stolen property. Defendant appealed, arguing that the judge erred in denying his motion to suppress because the arrest warrants leading to the search of an apartment where the stolen property was discovered did not authorize the police to enter the apartment. Specifically, Defendant argued that the police did not have a “reasonable belief” that Defendant was present in the apartment, and therefore, the subsequent seizure of the stolen property was the fruit of this unconstitutional entry. The Supreme Court vacated the convictions and remanded, holding (1) a “reasonable belief” requires more than was known at the time of entry in this case; and (2) therefore, the entry was unconstitutional, and the observation and subsequent seizure of the stolen property allegedly received by Defendant should have been suppressed as the fruit of the illegal entry. View "Commonwealth v. Gentile" on Justia Law

Defendant was incarcerated for rape of a child when the Commonwealth filed a petition to have him declared a sexually dangerous person (SDP). Several months after the conclusion of a jury-waived trial, a superior court judge issued a decision concluding that Defendant was an SDP and ordering him committed to a treatment center. Defendant appealed, arguing, among other things, that the trial judge erred in failing to issue a decision within thirty days of the end of trial in accordance with Commonwealth v. Blake. The court of appeals affirmed. The Supreme Court affirmed, holding that although the trial judge’s decision was not issued within thirty days as required by Blake, neither dismissal of the Commonwealth’s petition nor a new trial was warranted under the circumstances. View "Commonwealth v. Pariseau" on Justia Law

After a second jury trial, Defendant was convicted of rape of a child. Prior to trial, Defendant moved to compel the production of psychological records of the complainant in the custody of the complainant’s psychologist. The motion judge denied the motion, concluding that statements by the complainant to her psychologist concerning the alleged assault, without more, did not meet the threshold requirements of Commonwealth v. Dwyer and Commonwealth v. Lampron. The court of appeals affirmed. The Supreme Court remanded the case to the superior court, holding that a summons for the production of the psychologist’s records related to the complainant’s sexual assault should have issued in this case. Remanded. View "Commonwealth v. Labroad" on Justia Law