Justia Criminal Law Opinion Summaries

Articles Posted in Massachusetts Supreme Judicial Court
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The Supreme Judicial Court affirmed Defendant's convictions of murder in the first degree and assault and battery by means of a dangerous weapon in the stabbing death of his former girlfriend, holding that there was no error warranting a new trial and no reason for the Court to exercise its extraordinary authority under Mass. Gen. Laws ch. 278, 33E.Specifically, the Supreme Judicial Court held (1) an expert's brief testimony concerning the legal definition of a mental disease or defect did not rise to the level of a substantial likelihood of a miscarriage of justice; (2) the trial judge did not abuse his discretion by not providing the jury a supplemental instruction distinguishing between a lack of criminal responsibility and diminished capacity; (3) there was no error in the instruction on the inference of an intent to kill that the jury could draw from the use of a dangerous weapon; and (4) the judge did not err in declining to instruct the jury to consider whether Defendant was incapable of resisting the urge to consume drugs or alcohol. View "Commonwealth v. Toolan" on Justia Law

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The Supreme Judicial Court reversed the order of the trial denying Defendant's motion to vacate global positioning system (GPS) monitoring as a condition of his probation, holding that the Commonwealth failed to establish how the imposition of GPS monitoring would further its interest in enforcing the court-ordered exclusion zone surrounding the victim's home.Defendant was convicted on two indictments charging him with rape and sentenced to a term of incarceration followed by probation. As a condition of probation, the judge ordered Defendant to submit to GPS monitoring pursuant to Mass. Gen. Laws ch. 265, 47. Defendant moved to vacate the condition of GPS monitoring on the ground that it constituted an unreasonable search. The trial judge denied the motion. The Supreme Judicial Court reversed, holding that the Commonwealth did not meet its burden of establishing the constitutionality of the warrantless search. View "Commonwealth v. Roderick" on Justia Law

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The Supreme Judicial Court affirmed Defendant's convictions for murder in the first degree on a theory of extreme atrocity or cruelty and denied his motion for a new trial, holding that there existed no grounds for reversal and that there was no reason to exercise the Court's authority under Mass. Gen. Laws ch. 33E to grant a new trial or to reduce the verdict.Defendant's first two trials ended in mistrials. At his third trial, the jury found Defendant guilty of murder and sentenced him to life in prison without the possibility of parole on the murder conviction. The Supreme Judicial Court affirmed, holding (1) trial counsel was ineffective for failing to file a motion to suppress certain evidence, but no substantial likelihood of a miscarriage of justice occurred; (2) the trial judge did not err in his evidentiary rulings; and (3) the evidence was sufficient to sustain the convictions. View "Commonwealth v. Melendez" on Justia Law

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The Supreme Judicial Court vacated the order of the Boston Municipal Court denying K.W.'s petition for expungement and remanded this matter to the municipal court, where an order shall enter allowing the petition for expungement and for further review, holding that the judge abused his discretion in concluding that expungement was not "in the best interests of justice."K.W. filed a petition seeking to have expunged two sets of criminal records involving charges or convictions of possession of an amount of marijuana that since has been decriminalized. The municipal court judge denied both petitions on the ground that it was not "in the best interests of justice" to expunge the records at issue. The Supreme Judicial Court reversed, holding (1) petitions for expungement that satisfy Mass. Gen. Laws ch. 276, 100K(a) are entitled to a strong presumption in favor of expungement; and (2) petitions for expungement in such cases may be denied only if a significant countervailing concern is raised in opposition to the petition. View "Commonwealth v. K.W." on Justia Law

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The Supreme Judicial Court affirmed the judgment of the superior court in favor of the parole board as to Plaintiff's appeal from the board's fourth denial of his request for parole, holding that the superior court correctly affirmed the board's decision to deny Plaintiff release on parole.After a retrial, Plaintiff was convicted of rape and assault and battery by means of a dangerous weapon for crimes he committed when he was sixteen years old. He was sentenced to life imprisonment with the possibility of parole. In denying Plaintiff's fourth request for parole, the board concluded that he was not yet rehabilitated and that his release was not compatible with the welfare of society. The superior court affirmed. The Supreme Judicial Court affirmed, holding that Plaintiff was not entitled to relief as to any of his arguments on appeal. View "Rodriguez v. Mass. Parole Board" on Justia Law

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The Supreme Judicial Court held that under the plain language of Mass. Gen. Laws ch. 119, 68 a juvenile defendant who is charged with murder and a properly-joined nonmurder offense must be committed to the custody of the sheriff if the defendant is not released on bail.Defendant, who was sixteen years old at the time of the offense, was charged with murder in the first degree and armed assault with intent to rob. At issue was whether the superior court judge had discretion to craft a bail order releasing Defendant on personal recognizance on the murder charge and ordering him to be held without bail on the related nonmurder charge such that he may continue to be held by the Department of Youth Services after his eighteenth birthday. The superior court judge concluded that he lacked the discretion to craft such a bail order and committed Defendant to the custody of the sheriff under Mass. Gen. Laws ch. 119, 68. The Supreme Judicial Court affirmed, holding that that plain language of the statute required that the superior court judge commit Defendant to the custody of the sheriff. View "Nicholas-Taylor v. Commonwealth" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the trial court denying Defendant's motion to dismiss the indictments against him charging him with involuntary manslaughter and other crimes, holding that the evidence presented to the grand jury was sufficient to support the indictment.While Defendant and his friend attempted to rob a taxicab driver the cabdriver shot and killed Defendant's accomplice. A grand jury returned indictments charging Defendant with involuntary manslaughter for the death of his friend. Defendant filed a motion to dismiss, arguing that the common-law limitation on homicide liability set forth in Commonwealth v. Campbell, 7 Allen 541 (1863), extends to the crime of involuntary manslaughter. The trial court denied the motion. The Supreme Court affirmed, holding that Campbell and its progeny do not preclude an indictment for wanton or reckless involuntary manslaughter where the deceased is killed by someone resisting a felony. View "Commonwealth v. Dawson" on Justia Law

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The Supreme Judicial Court vacated the order of the trial court denying Defendant's motion for a new trial, holding that Defendant received constitutionally ineffective assistance of counsel during trial and that remand to the superior court was required for Defendant to receive a new trial.After a jury trial, Defendant was convicted of murder in the first degree and firearm offenses. During the trial, defense counsel disclosed confidential information to the Commonwealth regarding the location of "key incriminating evidence." Defendant filed a motion for a new trial, alleging that he had received constitutionally ineffective assistance of counsel because he had not given his counsel his informed consent to disclose the information. The superior court denied the motion. The Supreme Judicial Court vacated the superior court's judgment, holding (1) because defense counsel did not present Defendant with any other option than disclosing the existence of the incriminating evidence Defendant's purported consent to the disclosure was neither adequately informed nor voluntary; and (2) because trial counsel mistakenly believed he had a duty to disclose the incriminating evidence and did not obtain Defendant's prior consent to making that disclosure, an actual conflict of interest existed rendering the representation constitutionally ineffective. View "Commonwealth v. Tate" on Justia Law

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The Supreme Judicial Court held that because both offenses may be committed recklessly, manslaughter and assault and battery by means of a dangerous weapon causing serious bodily injury are not predicate offenses under the force clause of Mass. Gen. Laws ch. 276, 58A(1).While he was driving, Defendant struck several parked and moving vehicles, as well as a pedestrian who died as a result of the collision. Defendant was charged with crimes arising to that incident. The Commonwealth moved for pretrial detention pursuant to Mass. Gen. Laws ch. 276, 58A, the dangerousness statute. At issue was whether the "force clause" of the statute includes the crimes of manslaughter and assault and battery by means of a dangerous weapon causing serious bodily injury. The Supreme Judicial Court affirmed Defendant's convictions, holding that a crime that may be committed with a mens rea of recklessness does not fall within the ambit of the force clause in Mass. Gen. Laws ch. 276, 58A(1). View "Commonwealth v. Escobar" on Justia Law

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The Supreme Judicial Court affirmed Defendant's convictions, holding that a defendant may be convicted of human trafficking under Mass. Gen. Laws ch. 265, 50(a) only if the jury finds that the defendant knowingly trafficked another person, whether or not that person is specifically identified.After a jury trial, Defendant was found guilty of five counts of human trafficking, five counts of deriving support from prostitution, four counts of keeping a house of ill fame, and three counts of money laundering. The Supreme Judicial Court affirmed, holding (1) the trial just did not err in denying Defendant's motion to sever her trial from that of her codefendants; (2) the trial judge did not err in declining to allow the introduction of testimony by two women before the grand jury; (3) the judge did not err in allowing the introduction of certain testimony; and (4) there was no prejudicial error in the jury instructions. View "Commonwealth v. Fan" on Justia Law