Justia Criminal Law Opinion Summaries

The Supreme Judicial Court affirmed the order of a single justice of the court denying Petitioner's petition filed pursuant to Mass. Gen. Laws ch. 211, 3, holding that nothing in Petitioner's petition required exercise of the court's extraordinary power of general superintendence.Petitioner, who was indicted for murder in the first degree and related offenses, filed a document entitled "Notice of Default and Opportunity to Cure re affidavit -- 'Writ of Quo Warranto' re Proof of Claim/Jurisdiction'" claiming that the courts of the Commonwealth lacked jurisdiction over him. The superior court judge denied the petition. Thereafter, Petitioner brought this petition seeking review. A single justice denied the petition. The Supreme Judicial Court affirmed, holding that the single justice was warranted in denying this Mass. Gen. Laws ch. 211, 3 petition. View "Wallace v. Commonwealth" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of one count of murder in the first degree on the theories of deliberate premeditation, extreme atrocity or cruelty, and felony murder, holding that there was no prejudicial error or reason to grant relief under Mass. Gen. Laws ch. 278, 33E.Specifically, the Supreme Judicial Court held (1) the trial judge did not abuse his discretion in finding Defendant competent to stand trial over defense counsel's objections; (2) Defendant was not prejudiced by the jury instructions concerning the consequences of a verdict of not guilty due to lack of criminal responsibility; and (3) the jury were entitled to conclude that Defendant was criminally responsible, and this Court declines to reduce the degree of guilt, order a new trial, or grant other relief under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Beatty" on Justia Law

The Supreme Judicial Court held that a defendant who has been serving the incarcerated portion of an illegal sentence imposed by the appellate division of the superior court has the same double jeopardy protections as a defendant who has been serving the incarcerated portion of an illegal sentence imposed by a single superior court judge.Defendant was convicted of indecent assault and battery. The appellate division revised Defendant's sentence by reducing the period of incarceration on two counts to from four to six years in prison. After it was discovered that Defendant's sentence was illegal the appellate division reversed the incarcerated portion of Defendant's sentence to concurrent terms of from five to six years. Defendant filed a petition under Mass. Gen. Laws ch. 211, 3 arguing that his resentence violated common-law principles of double jeopardy. The single justice denied the petition. The Supreme Judicial Court reversed, holding (1) when sufficient time has lapsed even an illegal sentence becomes final, and double jeopardy principles preclude the State from making upward adjustments to the sentence; and (2) Defendant was entitled to judgment on his petition. View "Martin v. Commonwealth" on Justia Law

In this action brought by the Commonwealth seeking relief from a trial court order requiring it to disclose information regarding a confidential informant the Supreme Judicial Court held that the motion judge in this case abused her discretion by failing to conduct the two-stage inquiry applicable to motions for disclosure of information subject to the Commonwealth's assertion of the informant privilege.After an informant notified police that Defendant was dealing crack cocaine Defendant was charged with a drug-trafficking offense and unlicensed operation of a motor vehicle. Defendant moved for disclosure of the name and address of the informant, as well as details relating to the informant's credibility. The motion judge allowed the motion. The Supreme Judicial Court reversed, holding that (1) the motion judge abused her discretion by failing to conduct the two-stage inquiry applicable to motions for disclosure of information subject to the Commonwealth's assertion of the informant privilege; and (2) the information sought was not sufficiently material or relevant to the defense to warrant the Commonwealth's assertion of the privilege. View "Commonwealth v. Gandia" on Justia Law

The Supreme Judicial Court remanded this case to the county court for entry of a judgment reversing the order of the motion judge allowing Defendant's motion for discovery and requiring the Commonwealth to disclose information about a confidential informant, holding that the Commonwealth's invocation of the informant privilege was proper. In obtaining a search warrant that led to the seizure of firearms from Defendant's apartment and Defendant's ensuing arrest on firearms and ammunition charges, the Commonwealth relied on information from the informant at issue. After he was charged, Defendant filed a motion seeking discovery of offers made to the informant and documents related to the informant's participation in other criminal investigations. The motion judge allowed the motion. The Supreme Judicial Court reversed, holding that the motion judge abused her discretion in granting the motion because the requested information would effectively disclose the informant's identity and Defendant failed to show that the informant was relevant and material to her defense. View "Commonwealth v. Whitfield" on Justia Law

The Supreme Judicial Court vacated the order of the motion judgment dismissing indictments against Derrick Gentry-Mitchell and Joseph Sullivan, Springfield police department officers, charging them with misleading investigators, holding that the indictments did not violate article 12 of the Declaration of Rights of the Massachusetts Constitution.In dismissing the indictments charging misleading investigators, the motion judge, citing Commonwealth v. Barbosa, 421 Mass. 547 (1995), concluded that the indictments presented the possibility that Defendants might be convicted of a felony offense without first being indicted of the same by a grand jury because the indictments charged multiple acts in a single count. The Supreme Judicial Court reversed and remanded this case for further proceedings, holding (1) the indictments charged the essential crime of willfully misleading investigators to impeded the investigation of the same underlying event - the alleged assault of the victim by Defendants, who were off duty at the time; (2) the misleading statements constituted a continuing course of conduct actuated by a single, continuing impulse or intent, or general scheme to conceal that event; and (3) therefore, the indictments did not violate article 12. View "Commonwealth v. Sullivan" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of unlawful possession of a firearm, holding that the did not abuse its discretion in denying Defendant's motion for discovery, and there was no error in the proceedings below warranting a new trial.Defendant's conviction arose from a police investigation into a report of a shooting in a crowded residential area and the ensuing discovery of a firearm allegedly discarded by Defendant. Before trial, Defendant filed a motion for discovery of police reports that he argued was relevant and material to the question of whether the investigation was motivated by race, in violation of his constitutional equal protection rights. The trial judge denied the motion, and Defendant was subsequently convicted. The Supreme Judicial Court affirmed, holding (1) there was no abuse of discretion in the denial of Defendant's motion for discovery; and (2) some of the prosecutor's remarks during closing argument were improper, but the remarks did not warrant a new trial. View "Commonwealth v. Cuffee" on Justia Law

The Supreme Judicial Court affirmed the denial of Defendant's motion to suppress evidence seized from his person during a stop and pat-frisk, holding that the new standard adopted in Commonwealth v. Long, 485 Mass. 711, 724-725 (2020), is applicable in the context of police investigations such as pedestrian stops in addition motor vehicle stops.Defendant was indicted on firearm-related charges after he was stopped by police officers while walking. In his motion to suppress, Defendant argued that the stop was unconstitutional because the officers lacked reasonable suspicion and because statistical evidence proved the officers were more likely to stop Black members of the community than individuals of other races. In addressing Defendant's equal protection challenge, the lower court presumed that this Court's standard for establishing an equal protection claim under the Massachusetts Declaration of Rights, which was adopted to provide a defendant a more accessible path to pursuing an equal protection claim in the context of a motor vehicle stop, applied equally to this pedestrian stop challenge. The Supreme Judicial Court affirmed, holding (1) the new standard adopted in Long is applicable in this case; and (2) the evidence supported the trial court's determination that the officers stopped Defendant to investigate his involvement in the shooting and not because of his race. View "Commonwealth v. Robinson-Van Rader" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court convicting Defendant of murder in the first degree on a theory of extreme atrocity or cruelty and declined to grant relief under Mass. Gen. Laws ch. 278, 33E, holding that Defendant was not entitled to relief on his claims of error.On appeal, Defendant argued that his motions for a required finding should have been allowed because there was insufficient evidence to support a finding that he was the perpetrator. The Supreme Judicial Court disagreed, holding (1) the Commonwealth met its burden to prove that there was sufficient evidence for the jury to find, beyond a reasonable doubt, that Defendant had killed the victim; and (2) the trial judge did not abuse her discretion in allowing the introduction of certain evidence. View "Commonwealth v. MacCormack" on Justia Law

The Supreme Judicial Court held that a closed case that ends in an acquittal, a no bill from a grand jury, or a finding of no probable cause by the court is not a record subject to a presumption of access under the First Amendment and that the Legislature clearly abrogated the common-law presumption of access with respect to these records by its plain language in Mass. Gen. Laws ch. 276, 100C.Defendant was arraigned on two counts of rape while armed with a firearm and other crimes. A jury acquitted Defendant on one count of rape while armed, assault with intent to rape, and carrying a firearm without a license and deadlocked on the remaining three counts, resulting in a mistrial. The Commonwealth ultimately filed a nolle prosequi. Defendant later brought his section 100C petition to seal his criminal record as to the counts on which he was acquitted and the courts for which the nolle prosequi was filed. A judge denied the petition. The Supreme Judicial Court remanded the case for further proceedings, holding that, regarding the counts in which the nolle prosequi was entered, the judge abused his discretion when weighing the relevant interests and factors. View "Commonwealth v. J.F." on Justia Law