Justia Criminal Law Opinion Summaries

In 2020, a police officer applied for a criminal complaint in the District Court, alleging that the defendant possessed a loaded firearm while intoxicated. A clerk-magistrate denied the application, finding no probable cause that the defendant had a firearm under his control inside a motor vehicle. No review of this decision was sought. Over two years later, the same officer filed a new application for the same offense with the same facts, and a different clerk-magistrate found probable cause and issued the complaint.The defendant filed a petition for extraordinary relief, arguing that the issuance of the complaint was barred by collateral estoppel and that the delay violated his due process rights. A single justice of the county court reserved and reported the petition to the full court.The Supreme Judicial Court of Massachusetts held that the principles of collateral estoppel did not bar the issuance of the complaint because the initial denial was not a final judgment. The court noted that a District Court determination of no probable cause is not conclusive and does not bar a subsequent indictment for the same offense. The court also found no due process violation, as the defendant did not have a constitutionally protected interest in the finality of a show cause determination, and the delay did not cause severe prejudice to the defendant's ability to mount a defense. The court remanded the case to the county court for entry of a judgment denying the defendant's petition for extraordinary relief. View "Cabrera v. Commonwealth" on Justia Law

Elena Gaston was indicted on charges of trafficking persons for sexual servitude, conspiracy, deriving support from prostitution, and money laundering. The Commonwealth alleged that she ran an escort service where her employees provided sexual services for money. On the day of her trial, a plea agreement was proposed, but during the plea colloquy, Gaston denied key elements of the charges, leading the judge to proceed to trial. During the trial, defense counsel made improper opening statements, conceding Gaston's guilt and inviting the jury to consider irrelevant factors, which led the Commonwealth to move for a mistrial.The trial judge initially opted for a curative instruction instead of a mistrial but later declared a mistrial after concluding that defense counsel's actions constituted ineffective assistance of counsel. The judge noted that defense counsel's failure to consult with Gaston on his opening statement and the detrimental impact of his strategy on her defense warranted a mistrial. Gaston, represented by new counsel, filed a motion to dismiss the indictments on double jeopardy grounds, which the trial judge denied.Gaston then filed a petition in the county court seeking relief from the denial of her motion to dismiss. The petition was denied by a single justice, and she appealed to the Supreme Judicial Court. The Supreme Judicial Court affirmed the single justice's decision, holding that the trial judge did not abuse his discretion in declaring a mistrial due to manifest necessity. The court found that the trial judge carefully considered alternatives and provided both parties with opportunities to be heard before declaring a mistrial. The court concluded that defense counsel's conduct was manifestly unreasonable and deprived Gaston of a substantial ground of defense, justifying the mistrial. View "Gaston v. Commonwealth" on Justia Law

The case involves the execution of an anticipatory search warrant that led to the seizure of cocaine and U.S. currency from Victor Manuel Mercedes' apartment. The warrant was contingent on a future triggering event, which did not occur. The issue is whether the police could still search the apartment based on other information in the warrant affidavit that independently established probable cause.In the Superior Court, a grand jury indicted the defendant on drug trafficking charges. A codefendant's motion to suppress evidence from a related search was granted, and the defendant joined this motion. The judge allowed the motion, ruling that the anticipatory warrant was void because the triggering event did not occur. The Commonwealth appealed, arguing that the search was valid based on probable cause from other information in the affidavit.The Supreme Judicial Court of Massachusetts reviewed the case. The court held that under Article 14 of the Massachusetts Declaration of Rights, police cannot execute an anticipatory search warrant without the occurrence of the specified triggering event or its equivalent. The court emphasized that the triggering event must be clear and narrowly defined to prevent police from exercising unfettered discretion. The court affirmed the lower court's decision to suppress the evidence, ruling that the anticipatory warrant was void without the triggering event, and no valid exception to the warrant requirement was established. The defendant's cross-appeal was dismissed. View "Commonwealth v. Mercedes" on Justia Law

In 2023, Boima Collins was convicted by a jury of carrying a firearm without a license and other charges. The Commonwealth introduced evidence of Collins' 1998 felony conviction to prove he did not have a license to carry a firearm, as a prior felony conviction bars one from obtaining such a license. The trial judge admitted the redacted court record over Collins' objection and instructed the jury to consider this evidence only for determining whether Collins had a license.Collins appealed, arguing that the trial judge abused her discretion by admitting the prior conviction evidence, claiming it was more prejudicial than probative and that the Commonwealth had less prejudicial means to prove lack of licensure. He also contended that the jury should have been instructed to consider the prior conviction evidence only if the Commonwealth proved beyond a reasonable doubt that he was the person named in the record. Additionally, Collins argued that the evidence was insufficient to prove he lacked a license because the Commonwealth did not prove he was the same person named in the record.The Supreme Judicial Court of Massachusetts reviewed the case and found no prejudicial error in admitting the evidence of Collins' prior conviction. The court held that the trial judge correctly weighed the evidence's probative value against the risk of unfair prejudice, provided robust limiting instructions to the jury, and noted that the prior conviction was for a dissimilar offense, reducing the risk of improper propensity reasoning. The court also concluded that the judge's instructions to the jury were not erroneous and that the evidence was sufficient to prove Collins lacked a firearms license. Consequently, the court affirmed Collins' convictions. View "Commonwealth v. Collins" on Justia Law

The defendant was convicted of assault and battery by means of a dangerous weapon after stabbing his father at a family barbecue. The incident occurred when the victim became upset and yelled at the defendant's wife, leading to a confrontation between the defendant and the victim. The victim pushed the defendant first, and the defendant responded by stabbing the victim in the chest. The defendant claimed he acted in self-defense and sought to introduce evidence of the victim's subsequent violent act to support his claim.The case was initially tried in the Superior Court, where the defendant was convicted. The judge denied the defendant's motion to introduce evidence of the victim's subsequent violent act, concluding that such evidence was not admissible under Commonwealth v. Adjutant. The defendant appealed, and the Supreme Judicial Court transferred the case from the Appeals Court on its own initiative.The Supreme Judicial Court of Massachusetts reviewed the case and held that the judge erred in believing that Adjutant evidence is not applicable to subsequent acts of violence. However, the court affirmed the conviction, stating that the evidence was correctly excluded because the identity of the first aggressor was not in dispute, and the defendant was the first to use deadly force. The court also held that the judge did not err in failing to instruct the jury on defense of another, as the defendant did not rely on this theory at trial, and no evidence suggested that the defendant reasonably believed he had to use deadly force to protect his wife. The judgment was affirmed. View "Commonwealth v. Andrade" on Justia Law

The case involves the admissibility of location data obtained from a GPS device imposed on the defendant as a condition of pretrial release. The defendant was involved in a domestic violence incident on December 26, 2019, where he threatened his ex-wife, C.P., and discharged a firearm. He was later apprehended in July 2020 and released on bail with conditions, including GPS monitoring. In August 2020, following a shooting incident, police retrieved the defendant's GPS data to determine his proximity to the crime scene.The Superior Court denied the defendant's motion to suppress the GPS evidence, and he entered a conditional guilty plea, reserving the right to appeal the suppression ruling. The case was transferred to the Supreme Judicial Court of Massachusetts.The Supreme Judicial Court addressed two main issues: whether the initial imposition of GPS monitoring was an unreasonable search under Article 14 of the Massachusetts Declaration of Rights, and whether the subsequent retrieval and review of the defendant's GPS data constituted an unreasonable search.The court held that the initial imposition of GPS monitoring was a search but was reasonable under Article 14 due to the legitimate governmental interests in protecting the alleged victims and ensuring compliance with the conditions of pretrial release. The court found that the defendant's privacy expectations were outweighed by these interests.Regarding the retrieval and review of the GPS data, the court concluded that it did not constitute a search under Article 14. The defendant did not have a reasonable expectation of privacy in the specific location data retrieved, as it was limited in scope and duration, and the defendant was aware that his movements could be monitored for compliance with pretrial conditions.The Supreme Judicial Court affirmed the lower court's order denying the motion to suppress. View "Commonwealth v. Govan" on Justia Law

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