Justia Criminal Law Opinion Summaries

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

The defendant was found guilty of first-degree murder, improper disposal of a body, and willfully misleading a police officer. The case involves the killing of a long-time friend, whose body was discovered by a passerby in a wooded area. The victim was identified through fingerprint records, and his cause of death was determined to be acute cyanide toxicity. The investigation revealed that the defendant and the victim had met on the day of the victim's death, and the defendant had given inconsistent and false statements to the police about their meeting.In the Superior Court, the defendant's pretrial motions to suppress evidence obtained from searches and his statements to the police were denied. The trial proceeded with the Commonwealth presenting evidence of the defendant's financial troubles and his purchase of cyanide. The defense argued that the defendant's confessions were not voluntary due to his medical and emotional state following a suicide attempt. The jury found the defendant guilty on all charges, and he was sentenced to life in prison for the murder conviction, with concurrent sentences for the other charges.The Supreme Judicial Court of Massachusetts reviewed the case. The defendant argued that the evidence obtained from the searches should have been suppressed due to lack of probable cause and that his statements to the police were involuntary. The court found no error in the denial of the motions to suppress, concluding that the affidavits provided sufficient probable cause and that the defendant's waivers of his Miranda rights and his statements were voluntary. The court affirmed the defendant's convictions and declined to order a new trial or reduce the conviction. View "Commonwealth v. Camuti" on Justia Law

The case involves a defendant who was convicted of multiple charges following an altercation involving a woman and three men, including the defendant and the victim. The defendant was found guilty of assault with intent to maim, mayhem, assault and battery by means of a dangerous weapon (knife) causing serious bodily injury, assault and battery by means of a dangerous weapon (shod foot), two counts of assault and battery, and misleading a police officer. The incident occurred after the defendant drove the intoxicated woman to her home, where a violent confrontation ensued with the victim.In the Superior Court, the defendant was convicted by a jury on the aforementioned charges. The defendant appealed, raising three issues: the exclusion of Adjutant evidence, the sufficiency of evidence for the conviction of misleading a police officer, and the duplicative nature of certain convictions. The Supreme Judicial Court granted direct appellate review.The Supreme Judicial Court of Massachusetts reviewed the case and held that the trial judge did not abuse his discretion in excluding the Adjutant evidence related to the defendant's self-defense claim and declined to extend the Adjutant rule to defense of another. The court found insufficient evidence to support the conviction of misleading a police officer, as the defendant's simple denial did not demonstrate specific intent. The court also determined that the convictions for assault with intent to maim and assault and battery by means of a dangerous weapon causing serious bodily injury were duplicative of the mayhem conviction, and one of the assault and battery convictions was duplicative of the assault and battery by means of a dangerous weapon conviction. Consequently, the court vacated the convictions for misleading a police officer, assault with intent to maim, assault and battery by means of a dangerous weapon causing serious bodily injury, and one count of assault and battery, while affirming the remaining convictions and remanding the case for resentencing. View "Commonwealth v. Rateree" on Justia Law

A Cambridge police officer observed a black Mazda sedan with an unilluminated rear license plate and initiated a traffic stop. The driver, Natnael Zemene, and two passengers were removed from the vehicle for an inventory search, which revealed a bottle of tequila and a box of ammunition. During a subsequent pat frisk, a firearm was found under Zemene's foot. Zemene admitted ownership of the firearm and was arrested.Zemene was charged with possession of ammunition without a license, carrying a firearm without a license, carrying a loaded firearm without a license, unlicensed operation of a motor vehicle, and two civil motor vehicle infractions. He was found guilty of carrying a firearm without a license but not guilty of the other charges. The trial judge denied his motion for a required finding of not guilty and sentenced him to eighteen months in a house of correction. Zemene's post-trial motions were denied, and his sentence was stayed pending appeal.The Supreme Judicial Court of Massachusetts reviewed the case. Zemene argued that retrial on the charge of carrying a firearm without a license would violate the double jeopardy clause. The court held that the relevant legal change occurred with its decision in Commonwealth v. Guardado, not the U.S. Supreme Court's decision in New York State Rifle & Pistol Ass'n v. Bruen. Therefore, the double jeopardy clause did not bar retrial. The court affirmed the single justice's denial of Zemene's petition for relief. View "Zemene v. Commonwealth" on Justia Law

The defendant was observed by a state trooper driving at a high speed and was stopped. During the stop, the trooper noticed the defendant making movements that suggested he might be armed. The trooper conducted a patfrisk and found a firearm in the defendant's jacket pocket. The defendant was charged with carrying a firearm without a license and other related offenses. He filed a motion to suppress the firearm and a statement he made during the stop, which was denied. The defendant was convicted and sentenced to eighteen months in a house of correction.The defendant's trial occurred after the Supreme Court's decision in New York State Rifle & Pistol Ass'n v. Bruen but before the Massachusetts Supreme Judicial Court's decision in Commonwealth v. Guardado. The trial court denied the defendant's posttrial motion for a required finding of not guilty, and the defendant appealed. The Supreme Judicial Court granted direct appellate review.The Supreme Judicial Court of Massachusetts held that the defendant is entitled to a new trial. The court determined that the appropriate remedy for defendants convicted under G. L. c. 269, § 10 (a) after Bruen but before Guardado I is a new trial, not a required finding of not guilty. The court reasoned that the Commonwealth could not have known it needed to prove the absence of a firearms license at the time of the defendant's trial, as Guardado I had not yet been decided. The court also affirmed the denial of the defendant's motion to suppress the firearm, finding that the trooper had reasonable suspicion to conduct the patfrisk and probable cause to seize the firearm. The case was remanded for a new trial. View "Commonwealth v. Crowder" on Justia Law

The defendant was convicted of first-degree murder for killing his wife after discovering text messages between her and another man. The defense argued mental impairment, supported by an expert forensic psychiatrist's testimony. The defendant appealed his conviction and the denial of his motion for a new trial, claiming ineffective assistance of counsel for not pursuing a heat of passion defense and for inadequate preparation of the expert witness.The Superior Court jury found the defendant guilty, and the motion for a new trial was denied by another judge. The motion judge held that trial counsel's strategic decision to focus on the mental impairment defense was not manifestly unreasonable and that any prejudice from the expert's unprepared answer was mitigated by subsequent testimony.The Supreme Judicial Court of Massachusetts reviewed the case and found no abuse of discretion in the motion judge's decision. The court held that trial counsel's decision not to pursue a heat of passion defense was reasonable given the weak evidence supporting it and the stronger mental impairment defense. The court also found that any error in preparing the expert witness did not create a substantial likelihood of a miscarriage of justice. The court affirmed the conviction and the denial of the motion for a new trial. View "Commonwealth v. Fratantonio" on Justia Law

The defendant was convicted of first-degree murder and unlawful possession of a firearm. The murder occurred on July 4, 2018, when the victim was shot while watching fireworks with his wife. The shooter was a passenger in a Volkswagen driven by Michael Carleton. The car was registered to Carleton's girlfriend, and the defendant's fingerprints and DNA were found in the car. The shooter was seen entering the defendant's mother's apartment building immediately after the shooting.In the Superior Court, the defendant's pretrial motion to suppress evidence was denied, and he was subsequently convicted by a jury. The defendant appealed, raising several arguments, including insufficient evidence of identity, improper statements by the prosecutor, and errors in jury instructions.The Supreme Judicial Court of Massachusetts reviewed the case. The court found that there was sufficient evidence to identify the defendant as the shooter, including video footage, forensic evidence, and the defendant's connection to the car and the apartment building. The court also determined that the prosecutor's statements during opening and closing arguments, while forceful, did not improperly appeal to the jury's emotions or shift the burden of proof.The court acknowledged an error in the jury instruction regarding extreme atrocity or cruelty but concluded that it did not result in a substantial likelihood of a miscarriage of justice because the defendant was also convicted on the theory of deliberate premeditation. Additionally, the court found that the failure to instruct the jury on the Commonwealth's burden to prove the defendant did not have a firearms license warranted vacating the firearm conviction and remanding for a new trial on that charge.The court affirmed the first-degree murder conviction and vacated the firearm conviction, remanding it for a new trial. View "Commonwealth v. Phillips" on Justia Law

The defendant, a New Hampshire resident, was arrested in Massachusetts on November 8, 2021, for operating a motor vehicle under the influence of alcohol following a collision. During a search of his vehicle, a handgun and ammunition were found. The defendant did not have a Massachusetts nonresident firearm license and was charged with unlawful possession of a firearm under G. L. c. 269, § 10 (a). He moved to dismiss the charge, arguing that the nonresident licensing scheme violated his Second Amendment rights, relying on the U.S. Supreme Court's decision in New York State Rifle & Pistol Ass'n v. Bruen.The District Court judge allowed the motion to dismiss, concluding that the nonresident licensing scheme was unconstitutional as applied to the defendant. The judge found that the scheme violated the Second Amendment by imposing discretionary licensing requirements on nonresidents. The Commonwealth appealed, and the Supreme Judicial Court of Massachusetts granted direct appellate review.The Supreme Judicial Court of Massachusetts held that the Commonwealth's prior nonresident firearm licensing scheme, which allowed the State police colonel discretion to issue or deny licenses, violated the Second Amendment under the Bruen decision. The court noted that such discretionary "may issue" regimes are presumptively invalid and not supported by historical tradition. The court also found that the impermissible portions of the statute could not be severed from the remainder, rendering the entire scheme unconstitutional. Consequently, the court affirmed the dismissal of the charge against the defendant. View "Commonwealth v. Donnell" on Justia Law

The defendant, a New Hampshire resident, was involved in a vehicle accident in Massachusetts and was found in possession of an unlicensed firearm. He was charged with unlawful possession of a firearm and ammunition. The defendant filed a motion to dismiss, arguing that the Commonwealth's nonresident firearm licensing scheme violated his Second Amendment rights in light of the Supreme Court's decision in New York State Rifle & Pistol Ass'n v. Bruen. The motion judge allowed the motion to dismiss, and the Commonwealth appealed.The Supreme Judicial Court of Massachusetts reviewed the case. The court first determined that the defendant lacked standing to bring an as-applied challenge to the Commonwealth's nonresident firearm licensing scheme because he had not applied for and been denied a license under that scheme. The court then considered the merits of a facial challenge to the scheme.The court held that the Commonwealth's nonresident firearm licensing scheme is consistent with the Second Amendment. The scheme's purpose is to restrict access to firearms by demonstrably dangerous persons, which is consistent with the nation's historical tradition of firearm regulation. The court also found that the scheme's "shall issue" licensing regime, which requires nonresidents to meet specific criteria to obtain a license, is analogous to historical regulations such as surety and going armed laws.Additionally, the court held that the scheme does not violate the Fourteenth Amendment rights to travel and to equal protection. The differences in the treatment of resident and nonresident license applicants, such as license duration and processing times, are rationally related to the legitimate state interest of ensuring public safety.The Supreme Judicial Court reversed the motion judge's order allowing the defendant's motion to dismiss, upholding the constitutionality of the Commonwealth's nonresident firearm licensing scheme. View "Commonwealth v. Marquis" on Justia Law