Justia Criminal Law Opinion Summaries

The defendant was charged with operating a motor vehicle while under the influence of alcohol (OUI), third offense, resisting arrest, and three civil motor vehicle violations. After being stopped by police, the defendant exhibited signs of intoxication and was arrested. At the police station, he refused a breath test and was taken to a hospital where blood tests were conducted as part of his medical treatment. The police obtained a search warrant for the defendant's blood samples and sent them to the State police crime laboratory for analysis. The defendant moved to suppress the blood sample evidence, arguing he did not consent to the blood test.The motion to suppress was allowed by the lower court, which ruled that the blood sample and any analysis conducted by the State police were inadmissible. The Commonwealth obtained the defendant's medical records, which included the blood test results, and a forensic scientist converted these results to a blood alcohol content (BAC) percentage. The defendant moved to exclude this converted BAC evidence, and the trial judge agreed, reasoning that it was derived from suppressed evidence. The Commonwealth's motion for reconsideration was denied, and they petitioned for extraordinary relief.The Supreme Judicial Court of Massachusetts reviewed the case and held that the consent provision of General Laws c. 90, § 24 (1) (e), which requires a defendant's consent for the admissibility of blood or breath test results conducted by or at the direction of police, does not apply to the mathematical conversion of serum/plasma ethanol results from medical records to a BAC percentage. The court concluded that this conversion is not a "chemical analysis" as defined by the statute. Therefore, the converted BAC evidence is admissible, and the lower court's decision to exclude it was reversed. The case was remanded for further proceedings consistent with this opinion. View "Commonwealth v. Gannett" on Justia Law

In a joint trial, Markeese Mitchell, Pedro Ortiz, and Terrance Pabon were convicted of second-degree murder. Years later, they moved to interview a juror, alleging bias and concealment of material information during jury selection. The motion was denied, and the convictions were affirmed on appeal. Subsequently, the defendants filed motions for a new trial, citing additional evidence of the same juror's alleged bias. The motion judge conducted an evidentiary hearing, where the juror testified, and then denied the new trial motions. The defendants also moved to disqualify the trial judge, arguing a conflict of interest due to the judge's professional relationship with the prosecutor from their original trial, who had since become a Superior Court judge. This motion was also denied.The Appeals Court affirmed the orders denying the motions for a new trial and for disqualification. The Supreme Judicial Court granted further appellate review. The defendants argued that they were entitled to a new trial because the juror failed to provide an honest response to a material question during empanelment, and an honest response would have provided valid grounds for a challenge for cause. They also argued that the trial judge should have been disqualified due to a conflict of interest.The Supreme Judicial Court concluded that the trial judge did not abuse her discretion in denying the motions for a new trial or the motion for disqualification. The Court found that the juror's inaccurate answer was not dishonest and did not demonstrate bias. The Court also found that the trial judge's professional relationship with the former prosecutor did not create an appearance of partiality. Therefore, the orders denying the motions for a new trial and for disqualification were affirmed. View "Commonwealth v. Mitchell" on Justia Law

In the early morning of March 24, 2015, Kenneth Lopez was shot and killed on Dwight Street in Springfield. His body was discovered the next morning. Lee Manuel Rios was arrested nine days later and charged with murder, conspiracy to commit murder, and several firearms offenses. In February 2018, a jury convicted Rios of first-degree murder with extreme atrocity or cruelty and deliberate premeditation, sentencing him to life in prison without parole.Rios appealed his convictions, the denial of his motion to suppress mail intercepted by the jail, the denial of his posttrial motion for a new trial, and sought relief under G. L. c. 278, § 33E. He also sought a new trial on several firearms convictions in light of the decision in Commonwealth v. Guardado.The Massachusetts Supreme Judicial Court reviewed the case. The court found no reason to exercise its extraordinary power to grant a new trial or reduce Rios's conviction of first-degree murder. The court affirmed the murder conviction and other firearm offenses, as well as the orders denying his pretrial motion to suppress and posttrial motion for a new trial. However, the court vacated Rios's convictions under G. L. c. 269, § 10 (a) and (h) and remanded those charges for a new trial, in accordance with the decision in Guardado II. View "Commonwealth v. Rios" on Justia Law

The defendant was convicted by a jury of aggravated rape of a child and indecent assault and battery on a child under fourteen years old. The charges stemmed from the defendant's rape and sexual assault of his twelve-year-old granddaughter. The victim testified that the defendant assaulted her in his bedroom while her mother was out of the house. The victim reported the assault to a Department of Children and Families (DCF) social worker, which led to police involvement and the collection of DNA evidence from the bedding.The Superior Court admitted the DNA evidence, which confirmed the presence of the defendant's DNA but excluded the victim's DNA. The defense argued that the DNA evidence contradicted the victim's testimony and suggested that the victim fabricated the assault after seeing the defendant with his girlfriend. The jury convicted the defendant on all counts, and the defendant appealed.The Supreme Judicial Court of Massachusetts reviewed the case. The defendant argued that his confrontation rights were violated because a reviewing analyst testified about the findings of a nontestifying analyst concerning DNA testing. The court agreed that the testimony was admitted in error but concluded that the error did not result in a substantial risk of a miscarriage of justice. The court also addressed the defendant's argument that the judge abused his discretion in admitting evidence of a prior sexual assault by the defendant on the victim. The court found that the judge acted within his discretion in admitting the prior bad act evidence.The Supreme Judicial Court affirmed the judgments, holding that the admission of the DNA evidence and the prior bad act evidence did not warrant a new trial. The court concluded that the errors did not significantly impact the trial's outcome, given the overall strength of the victim's testimony and the limited nature of the prior bad act evidence. View "Commonwealth v. Nascimento-Depina" on Justia Law

The defendant crashed his vehicle into a State police cruiser parked in the breakdown lane on Interstate Route 90, resulting in the death of a trooper. The defendant was convicted of involuntary manslaughter, misdemeanor motor vehicle homicide by means of negligent or reckless operation, operating a motor vehicle so as to endanger the lives or safety of the public, and operating an uninsured motor vehicle. The defendant appealed, arguing that the Legislature did not authorize multiple punishments for involuntary manslaughter, motor vehicle homicide, and operating to endanger arising from the same act. He also contended that the evidence was insufficient to sustain his involuntary manslaughter conviction and that his trial counsel was ineffective.The Superior Court judge denied the defendant's motion for a new trial. The Appeals Court reversed the convictions of motor vehicle homicide and operating to endanger, holding that the Legislature did not intend to impose multiple punishments based on the same act for those offenses where a defendant is also convicted of involuntary manslaughter. The Appeals Court upheld the involuntary manslaughter conviction and rejected the defendant's arguments regarding the insufficiency of evidence and ineffective assistance of counsel.The Supreme Judicial Court of Massachusetts granted further appellate review. The court reaffirmed its holding in Commonwealth v. Jones, which precludes multiple punishments for involuntary manslaughter, motor vehicle homicide, and operating to endanger based on the same act. The court affirmed the defendant's convictions of involuntary manslaughter and operating an uninsured motor vehicle but reversed the convictions of motor vehicle homicide and operating to endanger. The court also affirmed the denial of the defendant's motion for a new trial, finding no ineffective assistance of counsel. View "Commonwealth v. Njuguna" on Justia Law

In this case, the defendant was convicted of first-degree murder. The incident occurred on February 6, 2006, when the victim was shot multiple times in an apartment building. Several witnesses, including Corrin Cripps, Jeanette Martinez, and Michael Gomes, identified the defendant as the shooter. Cripps and Martinez were using cocaine at the time of the incident, and Gomes initially failed to identify the defendant in a photographic array. The defendant was later found in Puerto Rico, where he provided an alias to the police.The defendant's conviction was previously affirmed by the Supreme Judicial Court of Massachusetts, along with the denial of his first motion for a new trial. In November 2022, the defendant filed a second motion for a new trial, arguing that newly discovered evidence regarding the unreliability of eyewitness identifications entitled him to a new trial. This motion was denied by a Superior Court judge, and the defendant sought leave to appeal from a single justice of the Supreme Judicial Court, which was granted on the issue of the new eyewitness identification science.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the denial of the second motion for a new trial. The court agreed that the new research on eyewitness identification was indeed newly discovered evidence. However, it concluded that this new evidence would not have been a real factor in the jury's deliberations. The court noted that the new research primarily addressed the unreliability of stranger identifications, which was only relevant to one of the three eyewitnesses. Additionally, the jury had already been made aware of the potential issues with the eyewitness identifications through cross-examination. The court also pointed out that there was other evidence of the defendant's guilt, including his intent and consciousness of guilt demonstrated by his actions after the shooting. Therefore, the court held that the absence of the new evidence did not cast real doubt on the justice of the conviction. View "Commonwealth v. Mercado" on Justia Law

In August 2021, five defendants responded to online advertisements offering sexual services for a fee. The advertisements, posted by undercover police officers, depicted an adult woman and listed various sexual services. Each defendant contacted the purported sex worker, selected services, agreed to the set price, and went to the specified location. Upon arrival, they were arrested by police officers.A Plymouth County grand jury indicted each defendant for trafficking of persons for sexual servitude under G. L. c. 265, § 50, and engaging in sexual conduct for a fee under G. L. c. 272, § 53A. The defendants moved to dismiss the sex trafficking charges, arguing that the facts did not support probable cause. A Superior Court judge allowed the motions, reasoning that the defendants did not attempt to traffic "another person" since the sex worker was an undercover officer. The Commonwealth appealed, and the Appeals Court affirmed the dismissal, concluding that the evidence did not constitute trafficking of a person for sexual servitude. The Commonwealth then sought further appellate review.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the dismissal of the sex trafficking indictments. The court held that the defendants' conduct of responding to advertisements, agreeing to terms, and going to the location did not constitute "trafficking of persons for sexual servitude" under G. L. c. 265, § 50. The court concluded that the statute did not apply to purchasers who respond to offers from independent sex workers and accept the terms set by the sex worker. The court emphasized that the statute targets those involved in the operation of sex trafficking schemes, not the subset of purchasers targeted by the sex for a fee statute. The case was remanded for further proceedings on the remaining indictments. View "Commonwealth v. Garafalo" on Justia Law

Two detectives from the Lowell police department, while investigating a home invasion in Lowell, Massachusetts, crossed into Nashua, New Hampshire, to speak with the defendant. During the conversation, one detective suspected the defendant was deleting data from his cell phone and seized it without a warrant. The detectives then brought the phone back to Massachusetts and obtained a warrant to search it.In the Superior Court, the defendant moved to suppress the evidence obtained from the cell phone, arguing that the seizure was unlawful. The motion judge allowed the motion, finding that the Lowell detectives had no authority to seize the phone in New Hampshire. The Commonwealth sought an interlocutory appeal, which was allowed by a single justice of the Supreme Judicial Court for the county of Suffolk. The case was then transferred to the Supreme Judicial Court on its own initiative.The Supreme Judicial Court of Massachusetts reviewed the case and concluded that the Lowell detective did not have extraterritorial authority to seize the cell phone in New Hampshire. The court found that no statutory or common law authority permitted the warrantless seizure in these circumstances. The court also rejected the Commonwealth's argument that the evidence would have been inevitably discovered, as this theory was not sufficiently supported by the record. The court held that suppression of the evidence was the appropriate remedy to deter police misconduct and preserve judicial integrity. The order allowing the motion to suppress was affirmed. View "Commonwealth v. McCarthy" on Justia Law

The defendant was convicted of deliberately premeditated murder in the first degree for the shooting death of Jesus Flores at the entrance of a Springfield nightclub. The primary issue at trial was the identification of the defendant as the shooter, which the Commonwealth supported with surveillance video footage. The defendant argued that the poor quality of the footage made it impossible to prove identification beyond a reasonable doubt.A Superior Court jury found the defendant guilty of murder in the first degree. However, the trial judge later reduced the verdict to murder in the second degree, citing insufficient evidence of deliberate premeditation and lethal intent. The defendant appealed, arguing that the evidence was insufficient to support the conviction, the compilation video was improperly admitted, and a police officer's testimony about a hearsay statement from the victim was wrongly allowed. The Commonwealth also appealed the reduction of the verdict.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the conviction of murder in the first degree. The court found that the evidence was sufficient for a rational jury to identify the defendant as the shooter and that the compilation video was properly admitted. The court also ruled that the victim's statement was admissible to rebut the defendant's challenge to the adequacy of the police investigation. Finally, the court reversed the trial judge's reduction of the verdict, reinstating the jury's original verdict of murder in the first degree, and remanded the case for resentencing. The court held that the weight of the evidence supported the jury's finding of deliberate premeditation and intent to kill. View "Commonwealth v. Gomez" on Justia Law

A juvenile was found delinquent on firearm charges and guilty on a youthful offender indictment for one of the offenses. At the trial, the juvenile was nineteen years old, and the Commonwealth called his mother to testify about events that occurred when he was seventeen. The juvenile argued that the parent-child witness disqualification statute, which prohibits testimony by a parent against their minor child, should have precluded his mother's testimony even though he was no longer a minor at the time of trial. He also claimed that the trial judge made several errors in admitting other evidence and that his sentence was unlawful and unconstitutional.The juvenile was charged in a delinquency complaint with possession of a firearm without a firearm identification card, unlawful possession of a large capacity feeding device, and improper storage of a firearm. He was subsequently indicted as a youthful offender for the large capacity feeding device charge. The juvenile filed a motion to prevent the Commonwealth from calling his mother as a witness, invoking the parent-child witness disqualification statute. The motion judge denied the motion, reasoning that the statute applied only to testimony against a minor child, and the juvenile was no longer a minor.The Supreme Judicial Court of Massachusetts reviewed the case and agreed with the trial judge's interpretation that the statutory prohibition of testimony by a parent against their minor child does not apply once the child has reached the age of eighteen. The court found no prejudicial error in the admission of other evidence, although it concluded that the judge should not have admitted a detective's testimony that a firearm depicted in still images was "identical" to the firearm admitted in evidence, nor two hearsay statements. Regarding the juvenile's sentence, the court agreed that the judge erred in not issuing written findings explaining the sentence but concluded that this error did not prejudice the juvenile. The court affirmed the juvenile's delinquency and youthful offender adjudications and declined to vacate his sentence. View "Commonwealth v. Rajiv R." on Justia Law