Justia Criminal Law Opinion Summaries

A lawful permanent resident was charged in 2015 with possession with intent to distribute and distribution of a class B substance in Massachusetts District Court. About a month after the charges, he admitted to sufficient facts for both offenses. At his plea colloquy, he was given a general warning that a conviction might lead to immigration consequences but was not explicitly warned that an admission to sufficient facts could also have such consequences. He also received a separate, more technical warning under a court rule, but not the specific statutory warning required under Massachusetts law. After the plea, federal authorities initiated deportation proceedings against him based on his admissions, though these proceedings were later dismissed due to a procedural defect, without prejudice.A motion judge in the District Court, who had not presided over the original plea, denied the defendant’s motion to withdraw his admissions. The judge reasoned that the defendant did not actually face the prospect of deportation as a result of the admissions. The defendant appealed, and the Supreme Judicial Court of Massachusetts granted direct appellate review.The Supreme Judicial Court of Massachusetts held that the defendant was entitled to withdraw his admissions to sufficient facts. The court concluded that the defendant did not receive the statutory warning required by G. L. c. 278, § 29D, which must advise noncitizen defendants that an admission to sufficient facts may have adverse immigration consequences. The court also held that the additional, technical warning provided was not a substitute for the statutory warning. Finally, the court found that the initiation of deportation proceedings by federal authorities demonstrated that the defendant actually faced the prospect of deportation. The court reversed the denial of the motion and remanded the case for further proceedings. View "Commonwealth v. Chhieng" on Justia Law

The case concerns a defendant indicted in two separate Superior Court proceedings for offenses including a violent home invasion and multiple firearm-related charges. The defendant was found incompetent to stand trial and unlikely to attain competency, based on several forensic psychological evaluations. While awaiting trial, the defendant was also charged with additional drug and firearm offenses in the Boston Municipal Court, which resulted in revocation of his bail in the Superior Court cases and the imposition of new cash bail. Following the expiration of the bail revocation, cash bail was set in the Superior Court cases, which the defendant could not post, resulting in his continued detention.After the Boston Municipal Court case was dismissed, the defendant remained detained solely due to his inability to post bail in the Superior Court cases. He petitioned a single justice of the Supreme Judicial Court for extraordinary relief, arguing that his continued detention, given his incompetency and unlikelihood of restoration, violated his substantive due process rights under the Massachusetts Declaration of Rights and the Fourteenth Amendment to the United States Constitution. The single justice denied relief, finding that the defendant’s detention had not yet exceeded a reasonable period necessary to determine the likelihood of competency restoration, and that the totality of circumstances—including the seriousness of the charges, time elapsed since prior evaluations, and the Commonwealth’s stated intention to seek a new evaluation—did not amount to a due process violation.On appeal, the Supreme Judicial Court of Massachusetts held that the framework articulated in Abbott A. v. Commonwealth, 458 Mass. 24 (2010), which limits the detention of incompetent defendants to the period necessary to assess the probability of restoring competency, applies regardless of whether detention arises from a finding of dangerousness or inability to post bail. The Court affirmed the judgment, concluding that no due process violation had occurred. View "In the Matter of an Impounded Case" on Justia Law

The case arose from a fatal stabbing at a bakery in Ludlow, Massachusetts. The defendant, a long-term employee of the bakery, stabbed the victim, who co-owned the bakery, after a series of workplace arguments. On the night of the incident, witnesses observed the defendant behaving normally before the attack. Surveillance footage captured the defendant deliberately retrieving a knife and repeatedly stabbing the victim. After the attack, the defendant resisted arrest but subsequently became calm and cooperative, providing coherent responses to police, and later to medical staff. The defendant had a documented history of psychiatric hospitalizations and had previously been diagnosed with major depression with psychotic features, but it was unclear whether he was taking medication at the time of the stabbing.The Commonwealth of Massachusetts Superior Court indicted the defendant for murder in the first degree and assault on a person over sixty with a dangerous weapon. At trial, the primary defense was lack of criminal responsibility due to mental illness. Competing expert testimony was presented on this issue. The jury convicted the defendant of murder in the first degree on a theory of deliberate premeditation but acquitted him of the assault charge. The defendant appealed, raising claims of judicial error regarding juror selection, the prosecution’s closing arguments, the admission of autopsy photographs, and the denial of his motion to suppress statements made post-arrest.The Supreme Judicial Court of Massachusetts reviewed the appeal. It held that there was no reversible error: the allegedly biased juror did not participate in deliberations; the prosecutor’s challenged statements were supported by the evidence and did not amount to improper argument; the autopsy photographs were properly admitted with limiting instructions; and the defendant’s statements were voluntary under the totality of the circumstances. The Court affirmed the conviction and declined to grant relief under G. L. c. 278, § 33E. View "Commonwealth v. Conza" on Justia Law

In this case, the defendant was convicted by a jury in 1972 of two counts of first-degree murder and one count of armed robbery, stemming from a fatal robbery at a supermarket in Dorchester, Boston. During the robbery, two security employees were shot and killed, and eyewitnesses identified the defendant as one of the perpetrators. Significant physical evidence linking the defendant to the crime was found shortly afterward, including stolen cash, murder weapons (one of which the defendant admitted owning), and the defendant himself at his sister’s apartment, where a wounded co-defendant was also present. The defense argued misidentification and denied participation in the crimes.Following the convictions, the defendant’s appeal was never perfected due to failures by both trial and appellate counsel. Later, the defendant escaped from custody in 1980, which resulted in the dismissal of his motion for a new trial. He was returned to custody in 1988 but did not promptly pursue appellate review. Decades later, the Supreme Judicial Court of Massachusetts permitted him to seek a motion for a new trial, treating any appeal from its denial as the functional equivalent of a direct appeal.The Supreme Judicial Court of Massachusetts reviewed the defendant’s claims of trial error under the law as it stood in 1980, allowing retroactive application of post-1980 legal developments only if the defendant was not at fault for the delay. The court found no reversible error in the jury instructions, the use of the prisoner's dock, the admission of certain evidence, or the prosecutor’s closing argument. The court also found no prejudice from alleged nondisclosure of an agreement with a prosecution witness. The court affirmed the denial of the motion for a new trial and concluded that no relief was warranted under its plenary review authority. View "Commonwealth v. White" on Justia Law

A high school student reposted on his public TikTok account an image depicting a man in a school hallway aiming an assault rifle, with the phrase “Me at School” across it. The image was seen by another student, the juvenile’s former girlfriend, who reported it to school officials because she found it frightening. This led to an investigation, a search of the juvenile’s home (with parental consent), and subsequent charges against the juvenile for communicating a threat against a place, in violation of Massachusetts General Laws chapter 269, section 14(b).The Middlesex County Division of the Juvenile Court Department heard the case. A jury found the juvenile delinquent. After the verdict, the judge vacated the finding, continued the case without a finding, and imposed probation conditions until the juvenile’s nineteenth birthday. The case was dismissed upon completion of probation, but the Supreme Judicial Court of Massachusetts allowed direct appellate review due to the possible collateral consequences of the delinquency complaint.The Supreme Judicial Court of Massachusetts held that, following the United States Supreme Court’s decision in Counterman v. Colorado, 600 U.S. 66 (2023), the Commonwealth must prove as an element of G. L. c. 269, § 14(b) that the defendant “consciously disregarded a substantial risk that his communications would be viewed as threatening violence.” The Court found that the jury had not been properly instructed on this requirement, constituting a substantial risk of a miscarriage of justice, even though the evidence was sufficient to support the adjudication. The Court remanded the case for further proceedings consistent with its opinion, clarifying the mens rea required for convictions under the statute. View "Commonwealth v. Ushon U." on Justia Law

Police officers in Boston, conducting surveillance as part of a drug investigation, observed an individual commit a civil traffic infraction while driving a vehicle. At the time, the officer who observed the infraction was in an unmarked vehicle and did not attempt to stop the car, citing safety concerns. The next day, the same officers resumed surveillance and, after locating the vehicle, requested a marked police cruiser to conduct a stop. During that stop, police discovered cocaine on the individual and in the vehicle. The investigation and subsequent search were not based on any new infractions or suspicious activity, but solely on the traffic violation observed the previous day.In the Superior Court Department, the defendant was indicted for trafficking cocaine. He moved to suppress the evidence obtained during the traffic stop, arguing that the twenty-four hour delay between the observed infraction and the stop rendered the seizure unreasonable under the Fourth Amendment and Article 14 of the Massachusetts Declaration of Rights. The motion judge denied the suppression motion regarding the physical evidence, finding the stop justified by the prior day’s infraction, and the defendant was convicted after a retrial.The Supreme Judicial Court of Massachusetts reviewed the case on direct appellate review. It held that, although some delay in conducting a traffic stop for safety reasons may be reasonable, the Commonwealth failed to justify the twenty-four hour delay in this case. The Court concluded that the stop violated Article 14 because the Commonwealth did not meet its burden to show the delay was reasonable under the totality of the circumstances. The Court reversed the portion of the order denying the motion to suppress, vacated the conviction, set aside the verdict, and remanded the matter to the Superior Court. View "Commonwealth v. Arias" on Justia Law

The case involves a dispute stemming from an incident where the defendant, after having moved out of the victim’s home following an altercation, unlawfully entered the victim’s residence several months later. The defendant had previously been allowed to live in the home rent-free, but was asked to leave after an argument and an arrest. On the date in question, the defendant persistently knocked on the victim’s doors before using keys, believed to have been taken from the victim’s unlocked car, to enter the locked house. Upon entry, the defendant retrieved personal items and, during an ensuing confrontation, drove off with a dog that had been given to the victim, injuring the victim in the process.The defendant was tried in the Westborough Division of the District Court Department, where she waived her right to a jury trial. The judge found her guilty of breaking and entering with intent to commit a misdemeanor, among other charges, though the Commonwealth did not specify which misdemeanor was intended. On appeal, the defendant argued there was insufficient evidence of intent to commit larceny, and the Commonwealth asserted the evidence supported intent to commit either larceny or criminal trespass. The Appeals Court found there was insufficient evidence of intent to commit larceny but affirmed the conviction based on sufficient evidence of intent to commit criminal trespass.The Supreme Judicial Court of Massachusetts reviewed the case, holding that the Commonwealth is not required to specify the intended misdemeanor at trial, and that proof of intent to commit an unspecified misdemeanor is sufficient under Massachusetts law. The court further held that, in a bench trial, the trial judge could consider any misdemeanor supported by the evidence. The court found sufficient evidence to infer intent to commit criminal trespass and affirmed the conviction. View "Commonwealth v. McGrath" on Justia Law

Late one evening, the defendant and two companions met with Bethgy Cator and Mayklens Francois in a Brockton parking lot for a marijuana transaction. After some negotiation, the defendant moved to Cator’s car, and the group drove off, with the defendant’s companions following in a separate vehicle. During the drive, the defendant testified that Francois pointed a gun at him and that both Cator and Francois threatened to rob him. After Cator pulled into a laundromat lot and made a sudden stop, the defendant claimed he saw Cator reaching for a gun. The defendant then drew his own gun and fired, killing Cator and injuring Francois, before fleeing the scene with his girlfriend. Ballistics evidence and surveillance video were collected; a .25 caliber firearm was recovered at the scene, but there was no evidence it was fired during the incident.At trial in the Massachusetts Superior Court, the defendant was convicted by a jury of murder in the first degree, assault with attempt to kill, and firearms offenses. The defendant argued on appeal that the trial judge mishandled the admission of hearsay statements made by Francois, the surviving victim, to police. The statements included Francois’s admission that he possessed a firearm during the confrontation and his explanation about disposing of it, which the defendant contended were central to his claim of self-defense. Initially, the judge excluded these statements as irrelevant unless the defendant testified, which led the defendant to take the stand.The Supreme Judicial Court of Massachusetts held that the trial judge erred in excluding Francois’s statements from the Commonwealth’s case-in-chief, as they were relevant to the defendant’s self-defense claim. The court found this error prejudicial, as it affected the defendant’s substantial rights and trial strategy. Consequently, the court vacated the convictions and remanded the case for a new trial, also vacating the firearms convictions in accordance with recent precedent. View "Commonwealth v. Williams" on Justia Law

In two separate cases, the defendants were charged with unlawful possession of large capacity firearms or feeding devices after police investigations uncovered evidence of such weapons. One defendant was found with multiple AR-15 style rifles, pistols, and high-capacity magazines in his home following a tip and search warrant. The other was arrested after a domestic disturbance, during which police discovered a loaded pistol with a fifteen-round magazine in his possession. Both defendants were indicted in the Superior Court Department for violations of G. L. c. 269, § 10 (m), among other offenses.Upon pleading guilty, each defendant was sentenced by a Superior Court judge to a State prison term of one year to one year and one day for the § 10 (m) violations. The Commonwealth objected to these sentences, arguing that the maximum term was unlawful because the statute requires a maximum term of at least two and one-half years. The Commonwealth filed timely motions to revise and revoke the sentences as illegal, but these were denied by the sentencing judges. The Commonwealth appealed, and the Supreme Judicial Court of Massachusetts transferred the cases from the Appeals Court on its own initiative.The Supreme Judicial Court of Massachusetts held that for convictions under G. L. c. 269, § 10 (m), the maximum term of an indeterminate State prison sentence must be at least two and one-half years. The court concluded that sentences with a maximum term less than two and one-half years are unlawful. It also held that principles of double jeopardy did not bar resentencing because the Commonwealth acted within the procedural time limits and the defendants did not have a legitimate expectation of finality in their sentences. The court reversed the denial of the Commonwealth's motions, vacated the sentences, and remanded for resentencing. View "Commonwealth v. Psikarakis" on Justia Law

A significant number of private attorneys who serve as court-appointed counsel for indigent defendants in two Massachusetts counties stopped accepting new cases to protest legislatively set compensation rates. This work stoppage resulted in hundreds of indigent defendants, including many in pretrial detention, being left without legal representation. The Committee for Public Counsel Services (CPCS), the entity charged with administering indigent defense, reported that the public defender division was at capacity and unable to fill the gap. CPCS petitioned for emergency relief, seeking both implementation of a protocol to address unrepresented defendants and a court-ordered increase in compensation rates for bar advocates.The Supreme Judicial Court for the county of Suffolk, through a single justice, conducted an evidentiary hearing, found a systemic violation of indigent defendants’ constitutional rights to counsel, and implemented the protocol requiring prompt hearings and potential release or dismissal when counsel could not be appointed in a timely manner. The single justice, however, denied the request to judicially increase rates, deferring to the Legislature. After a trial court judge unilaterally ordered higher rates for certain attorneys, the question of judicial authority to set such rates was reserved and reported to the full Supreme Judicial Court.The Supreme Judicial Court of Massachusetts held that neither it nor any other court has authority to order increased compensation rates for bar advocates above those set by the Legislature, absent extraordinary circumstances where the judiciary’s constitutional functioning is impaired and all other remedies are exhausted. The court found that the existing statutory rates, recent legislative rate increases, and incentive programs ensured a constitutionally adequate system and that judicially ordered rate increases would violate the separation of powers. The matter was remanded for further proceedings consistent with this opinion. View "Committee for Public Counsel Services v. Middlesex and Suffolk County District Courts" on Justia Law