Justia Criminal Law Opinion Summaries

The Supreme Judicial Court affirmed the order of the superior court denying Defendant's motion to suppress, holding that the articulable facts combined to establish reasonable suspicion that Defendant had committed armed robbery.At issue was whether information known to other investigating officers may be imputed to the officer who initiated the stop under the collective knowledge doctrine. The superior court judge denied Defendant's motion to suppress evidence obtained as a result of a stop, concluding that the officer who conducted an investigatory stop on Defendant had adequate reasonable suspicion to do so. The appeals court affirmed. The Supreme Judicial Court affirmed, holding that, with or without the imputed knowledge, the officer who stopped Defendant had reasonable suspicion to do so. View "Commonwealth v. Privette" on Justia Law

The Supreme Judicial Court affirmed the order finding Probationer in violation of his probation, revoking his probation and imposing the remainder of his suspended sentence, holding that the evidence was sufficient to for the superior court judge to find, by a preponderance of the evidence, that Probationer had violated a term of his probation by committing a new offense.On appeal, Probationer argued that the judge erroneously relied upon an unreliable, in-court identification by a witness who had made no prior, out-of-court identification. Specifically, Probationer asked the Supreme Judicial Court to extend the rule set forth in Commonwealth v. Crayton, 470 Mass. 228, 214 (2014), excluding such identifications in criminal trials without a showing of good reason to probation violation hearings. The Supreme Judicial Court affirmed, holding (1) this Court declines to extend Crayton to probation violation hearings; and (2) sufficient evidence supported the holding that Probationer had violated a term of his probation by committing a new offense. View "Commonwealth v. Jarrett" on Justia Law

The Supreme Judicial Court held that the single justice of the county court neither erred nor abused his discretion by denying, without a hearing, Petitioner's petition for relief under Mass. Gen. Laws ch. 211, 3, holding that the single justice neither erred nor abused his discretion by denying extraordinary relief.In 1985, Petitioner was convicted of aggravated rape and other offenses. In 2005, the Sex Offender Registration Board issued a decision ordering Petitioner to register as a level three sex offender, thereafter denying Petitioner's motion for relief from the registration requirement. In this petition, Petitioner brought, among other claims, constitutional challenges to both federal and state sex offender registration laws. The single justice denied relief. The Supreme Judicial Court affirmed, holding that the single justice did not abuse his discretion in finding that no exceptional circumstances were present in this case warranting extraordinary relief. View "Rancourt v. Attorney General" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court judge denying Defendant's motion to enforce a plea bargain, holding that the plea offer did not violate Defendant's rights to due process.Defendant was indicted along with two codefendants on two counts of murder in the first degree. Defendant was offered a "package deal" plea bargain under which he would have been able to plead guilty to manslaughter if his codefendant also agreed to the same plea. Defendant's codefendant refused the terms of the agreement. Defendant and his codefendant were tried and convicted of all charges. Defendant later filed a motion to vacate his convictions and to accept pleas to manslaughter, as the Commonwealth had originally offered, arguing that the condition attached to the plea offer violated his right to decide whether to accept the plea or go to trial. A superior court judge denied the motion. The Supreme Judicial Court affirmed, holding that the superior court did not err in denying Defendant's motion to enforce the plea bargain. View "Commonwealth v. DiBenedetto" on Justia Law

The Supreme Judicial Court remanded this matter to the county court for entry of an order dismissing the Commonwealth's gatekeeper petition filed under Mass. Gen. Laws ch. 278, 33E challenging the decision of the superior court judge granting Defendant's motion for postconviction relief and reducing his conviction, holding that the petition was untimely.Defendant served forty-four years in prison for his conviction of murder in the first degree. In 2020, Defendant filed a postconviction motion to reduce the verdict from murder in the first degree to murder in the second degree on the grounds that the Commonwealth's 1978 package plea offer violated his right to due process. The motion judge granted the motion and, in 2021, reduced the verdict to murder in the second degree. The Commonwealth filed a notice of appeal but did not file the gatekeeper petition until five and one-half months later, exceeding the thirty-day time limit set out in Mains v. Commonwealth, 433 Mass. 30, 36 n.10 (2000). After a remand, the single justice allowed the petition. The Supreme Judicial Court remanded the matter for entry of an order dismissing the Commonwealth's gatekeeper petition, holding that, with respect to filing deadlines, the Commonwealth is subject to the limitations established in Mains. View "Commonwealth v. Smith" on Justia Law

The Supreme Judicial Court vacated the order of the trial judge granting Defendant's motion to dismiss his criminal case for lack of prosecution and requiring the Commonwealth to file a motion to vacate it if decided to proceed with the prosecution of the case, holding that the judge's decision to require the Commonwealth to seek court approval before refiling charges was an abuse of discretion.Defendant was charged with operating a motor vehicle while under the influence, among other charges. After Defendant's trial was continued three times, he filed his motion to dismiss. The judge granted the motion and required the Commonwealth to file a motion to vacate if it chose to refile the case. The Commonwealth sought extraordinary relief under Mass. Gen. Laws ch. 211, 3, arguing that the underlying order violated the district attorney's authority to choose which cases to prosecute. The Supreme Judicial Court vacated so much of the order granting Defendant's motion to dismiss that required the Commonwealth to file a motion to vacate the dismissal, holding that the ruling constituted an unwarranted intrusion upon the powers granted exclusively to the executive branch under Article 30 of the Massachusetts Declaration of Rights. View "Commonwealth v. Rosa" on Justia Law

The Supreme Judicial Court affirmed the judgment of the motion judge allowing Defendant's motion for a new trial after the trial court convicted him of murder in the first degree, holding that the motion judge did not abuse her discretion in concluding that counsel's assistance was constitutionally ineffective.During the proceedings, counsel was informed of a proffer indicating that someone other than Defendant had gone to the victim's home on the evening of the killing and carrying the same caliber firearm as was used in the killing. In his motion for a new trial, Defendant argued that his counsel provided ineffective assistance by failing to investigate the exculpatory evidence provided by the Commonwealth. The motion judge allowed the motion. The Supreme Judicial Court affirmed, holding (1) use of the proffer evidence could have raised a reasonable doubt as to whether Defendant murdered the victim; and (2) therefore, the motion judge's denial of Defendant's motion for a new trial was an abuse of discretion. View "Commonwealth v. Tavares" on Justia Law

The Supreme Judicial Court affirmed the judgment of a single justice of the court denying Petitioner's petition pursuant to Mass. Gen. Laws ch. 211, 3, holding that the single justice did not err or abuse her discretion in denying relief.Petitioner was convicted of several crimes, including armed assault with intent to murder. The firearm leading to the charges was recovered during a motor vehicle search that led to charges in a separate case against a different individual, Danilo Depina, who successfully moved to suppress the firearm on the basis that it had been illegally seized. Petitioner later filed the underlying petition, which the county court treated as a petition pursuant to Mass. Gen. Laws ch. 211, 3, arguing that he had stand to petition the district attorney's office that had prosecuted Petitioner to produce evidence related to the firearm. A single justice denied the petition. The Supreme Judicial Court appealed, holding that there was no abuse of discretion in the denial of the appeal. View "Pina v. Commonwealth" on Justia Law

The Supreme Court affirmed Defendant's convictions for murder in the first degree on the theory of deliberate premeditation and related charges, holding that there was no reversible error in this Court's review of Defendant's direct appeal or Defendant's postconviction motion for a new trial.On appeal, Defendant challenged his convictions of murder in the first degree, armed assault with intent to murder, and assault and battery by means of a dangerous weapon causing serious bodily injury and further appealed the denial of his postconviction motion for a new trial. The Supreme Court affirmed, holding that Defendant's claims of error were unavailing and that there was no reversible error in the proceedings below. View "Commonwealth v. Kirkland" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on the theory of extreme atrocity or cruelty and his sentence of life without the possibility of parole, holding that Defendant's allegations of error were unavailing.Specifically, the Supreme Judicial Court held (1) the trial judge did not abuse his discretion in excluding proposed expert testimony regarding the general principles and characteristics of late adolescent brain development; (2) a challenged statement made by the prosecutor during closing arguments did not create a substantial likelihood of a miscarriage of justice; (3) Defendant was not entitled to an instruction on involuntary manslaughter; and (4) the jury did not apply an incorrect burden of proof in reaching their verdict; (5) this Court declines to address Defendant's challenge to the constitutionality of his sentence; and (6) this Court declines to exercise its extraordinary authority to reduce the conviction to murder in the second degree or voluntary manslaughter. View "Commonwealth v. Ridley" on Justia Law