Justia Criminal Law Opinion Summaries

The Supreme Court affirmed Defendant's convictions of two counts of murder in the first degree, holding that this Court's precedent on reasonable provocation based on sudden oral revelations of infidelity, and, relatedly, lack of paternity, is hereby disavowed.Defendant stabbed his girlfriend, who was nine months pregnant, killing her and her viable fetus. At issue at trial was whether the stabbing had been mitigated by "heat of passion upon reasonable provocation," thus reducing Defendant's liability to manslaughter, because his girlfriend falsely disclosed that he was not the father. The Supreme Court affirmed, holding (1) rational jurors could have found that the stabbings were not the result of a heat of passion upon reasonable provocation, and therefore, the evidence was sufficient to support Defendant's convictions; and (2) this Court no longer recognizes that an oral discovery of infidelity satisfies the objective element of something that would provoke a reasonable person to kill his or her spouse. View "Commonwealth v. Ronchi" on Justia Law

The Supreme Judicial Court held that the presumptive ninety-day time limit on pretrial detention set forth in Mass. Gen. Laws ch. 276, 58B begins to run at the time an individual is detained, regardless of whether a formal order of detention has entered.At issue in this case was whether the presumptive time limit on pretrial detention outlined in section 58B is calculated from when an individual is first detained or from when the order of detention formally issues. Defendant asked that the docket be corrected in his dismissed case to reflect that his ninety days of detention pursuant to section 58B began to run on the date of arraignment rather than the date that the formal order of detention issued. The request was denied. Defendant then brought this petition under Mass. Gen. Laws ch. 211, 3 seeking extraordinary relief. A single justice denied the petition. The Supreme Judicial Court affirmed, holding that, where section 58B is applicable, the ninety-day clock begins to run at the time a person is detained and his or her liberty is curtailed, not when the formal order is issued. View "Velazquez v. Commonwealth" on Justia Law

The Supreme Court affirmed Defendant's conviction of murder in the first degree on a theory of deliberate premeditation and declined to exercise its authority under Mass. Gen. Laws ch. 33E either to reduce the verdict or to grant Defendant a new trial, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Judicial Court held (1) Defendant's absence from substantive sidebar conferences was error on the part of the trial court, but the error was harmless; (2) the trial judge did not abuse his discretion in ruling that a challenged statement was inadmissible hearsay and failed to satisfy one of the exceptions to the hearsay rule; (3) the trial judge did not abuse his discretion in admitting expert testimony on Defendant's military record; (4) the closure of the courtroom during jury selection did not violate Defendant's constitutional right to a public trial; (5) Defendant received effective assistance of counsel; and (6) there was no reason for the Court to exercise its discretion to reduce Defendant's conviction to murder in the second degree. View "Commonwealth v. Ng" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court denying Defendant's motion for a new trial following his conviction for murder in the first degree by means of extreme atrocity or cruelty and on the theory of felony-murder, for which his conviction of armed robbery served as the predicate offense, holding that there was no error.During trial, the Commonwealth presented expert testimony comparing hair samples collected at the crime scene with hair taken from Defendant. The testimony included a statistical probability to support the expert's opinion that the hair at issue belonged to Defendant. Due to an ensuing development finding such statistical probabilities to support hair comparisons to be unreliable Defendant filed a motion for a new trial. The motion was denied. The Supreme Judicial Court affirmed, holding that the admission of expert testimony on statistical support for hair comparison evidence, which since has been proved to be unreliable, was not a real factor in the jury's deliberations. View "Commonwealth v. Eagles" on Justia Law

The Supreme Judicial Court affirmed the decision of a single justice of the court denying Petitioner's petition for extraordinary relief pursuant to Mass. Gen. Laws ch. 211, 3, holding that the trial justice did not commit a clear error of law or abuse his discretion in denying relief.Petitioner was convicted of armed assault with intent to murder and related charges. The Supreme Judicial Court remanded the case for a new trial, holding that the trial court prejudicially erred by admitting evidence of speed data from the GPS device worn by Petitioner. The second trial resulted in a mistrial. Petitioner filed a posttrial motion asking for a required finding of not guilty or for dismissal on double jeopardy grounds due to insufficient evidence. The trial judge denied the motion. Petitioner then brought this petition. The single justice denied relief. The Supreme Judicial Court holding (1) a rational trier of fact could reasonably infer from the evidence that Petitioner was the shooter; and (2) therefore, the single justice properly denied relief. View "Davis v. Commonwealth" on Justia Law

In this case involving Salvatore F. DiMasi's attempt to register as a lobbyist with the Secretary of the Commonwealth, the Supreme Judicial Court held that Mass. Gen. Laws ch. 3, 45 (m) ("the disqualification provision") limits automatic disqualification to individuals who have been convicted of a felony set forth in Mass. Gen. Laws ch. 3, 55 or 268A.In 2011, DiMasi was convicted of seven federal felonies arising from his sale of political favors while serving as Speaker of the Massachusetts House of Representatives. In 2019, after he was released from prison, DiMasi filed his application to register as a lobbyist. The Secretary denied the application, citing the disqualification provision. The Secretary determined that, even though DiMasi was convicted of federal offenses, his application for registration as a lobbyist must be rejected because the conduct underlying his convictions would have violated Mass. Gen. Laws ch. 3 or 268A. Thereafter, DiMasi brought this lawsuit. The Supreme Judicial Court held in favor of DiMasi, holding that Mass. Gen. Laws ch. 3, 45(m) does not afford the Secretary discretion to consider what other offenses might require automatic disqualification even if the underlying criminal conduct could support a felony conviction pursuant to Mass. Gen. Laws ch. 3, 55 or 268A. View "DiMasi v. Secretary of the Commonwealth" on Justia Law

The Supreme Judicial Court affirmed the decision of the juvenile court judge denying Juvenile's motion to suppress evidence of a seized firearm on the grounds that police did not have reasonable suspicion to stop her, holding that the juvenile court did not err.As a result of a report about kids displaying a firearm outside a housing complex four police officers were dispatched to the complex. One officer noticed Juvenile walking along the street who kept adjusting the waistband of her pants. The officers stopped her, conducted a patfrisk, and discovered a loaded firearm in Juvenile's waistband. After her motion to suppress was denied Juvenile entered a conditional guilty plea to four firearms-related offenses. The Supreme Judicial Court affirmed, holding that the officers had reasonable suspicion that Juvenile was carrying an illegal firearm in her waistband, and therefore, the stop and pat frisk of Juvenile comported with constitutional requirements. View "Commonwealth v. Karen K." on Justia Law

The Supreme Judicial Court affirmed the judgment of a single justice of the court denying Petitioner's petition filed pursuant to Mass. Gen. Laws ch. 211, 3, holding that the single justice did not err or abuse his discretion in denying relief.After a jury trial, Petitioner was convicted of kidnapping, rape of a child with force, and threatening to commit a crime. The convictions were affirmed on appeal. Petitioner later filed three motions for a new trial, all of which were denied. Petitioner then filed the instant petition arguing that the appeals court erred in affirming the denial of his third new trial motion. The single justice denied relief. The Supreme Judicial Court affirmed, holding that there was no error or abuse of discretion. View "Dumas v. Commonwealth" on Justia Law

The Supreme Judicial Court vacated the order of a single justice of the court vacating the superior court's order that Defendant could depose the licensed social worker who saw the complaining witness, Jonathan, after Jonathan told his parents that Defendant, his technology teacher, had touched him inappropriately, holding that it was not an abuse of discretion for the motion judge to order that the social worker be subjected to a limited deposition.Defendant was indicted on charges arising from Jonathan's allegations during an interview with the Sexual Assault Intervention Network. Defendant filed a motion to examine the treatment records of the social worker who treated Jonathan, but the records had been destroyed. In response, a judge ordered that Defendant would have the opportunity to depose the social worker. Jonathan filed a petition pursuant to Mass. Gen. Laws ch. 211, 3 seeking to block the deposition. A single justice vacated the order that the social worker could be deposed. The Supreme Judicial Court vacated the single justice's order and denied Jonathan's petition for extraordinary relief, holding that it was not an abuse of discretion for the motion judge to order that the social worker be subjected to a limited deposition. View "In re an Impounded Case" on Justia Law

In this case where Plaintiffs sought a declaration that the Massachusetts Constitution protects a fundamental right to physician-assisted suicide, thereby immunizing the practice from criminal prosecution, the Supreme Judicial Court held that the proposed right, as defined by Plaintiffs, was not supported in the relevant provisions of the Constitution.Plaintiffs were a licensed physician who wished to provide physician-assisted suicide and a retired physician who had been diagnosed with an incurable cancer. Plaintiffs brought a civil action seeking declaratory and injunctive relief, arguing that terminally ill patients with six months or less to live have a constitutional right to receive a prescription for lethal medication in order to bring about death in a manner and time of their choosing. The trial court granted summary judgment for Defendants. The Supreme Judicial Court affirmed, holding (1) the Massachusetts Declaration of Rights does not protect physician-assisted suicide; and (2) the law of manslaughter prohibits physician-assisted suicide without offending constitutional protections. View "Kligler v. Attorney General" on Justia Law