Justia Criminal Law Opinion Summaries

Articles Posted in Massachusetts Supreme Judicial Court
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In this case brought by incarcerated individuals challenging the conditions of confinement during the COVID-19 pandemic the Supreme Judicial Court allowed the parole board's motion to dismiss only with respect to the claims of the individuals civilly committed and allowed the Governor's motion to dismiss, holding that the Governor was not liable under the facts alleged. The complaint alleged that by confining Plaintiffs under conditions that put them in grave and imminent danger of contracting the COVID-19 virus and by failing to reduce the incarcerated population, Defendants were violating Plaintiffs' right to be free from cruel and unusual punishment and their right to substantive due process. Further, Plaintiffs alleged that confining persons who have been civilly committed under Mass. Gen. Laws ch. 123, 35 in correction facilities violates the individuals' rights to substantive due process. The Supreme Judicial Court (1) granted the Governor's motion to dismiss, holding that the Governor's presence was not necessary to provide any relief that a court may order in this case; and (2) allowed the parole board's motion to dismiss only with respect to the claims of individuals civilly committed, holding that if Plaintiffs' constitutional claims were to prevail, the parole board would be a logical and necessary party to accomplish a reasonable remedial process. View "Foster v. Commissioner of Correction (No. 2)" on Justia Law

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The Supreme Judicial Court denied Plaintiffs' motion for a preliminary injunction enjoining the Department of Correction (DOC) from housing prisoners in facilities where the population exceeds its design-rated capacity and from housing prisoners areas where they must live within six feet of another person, holding that, despite the COVID-19 pandemic, Plaintiffs were unlikely to succeed on the merits of their claim for violations of the Eighth Amendment. Plaintiffs, incarcerated inmates serving sentences or individuals who were civilly committed under Mass. Gen. Laws ch. 123, 35, commenced a class action alleging that their conditions of confinement exposed them to unreasonable risks from the COVID-19 pandemic. Specifically, Plaintiffs alleged that Defendants' failure to take steps to reduce the incarcerated population so as to permit adequate physical distancing constituted cruel and unusual punishment in violation of the Eighth Amendment and violated substantive due process requirements. Plaintiffs sought a preliminary injunction in their claims for unconstitutional conditions of confinement because of the risk of a disease. The Supreme Judicial Court denied the motion, holding that Plaintiffs were unlikely to succeed on the merits of their claim. The Court then transferred the case to the superior court for a final adjudication on the merits. View "Foster v. Commissioner of Correction (No. 1)" on Justia Law

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The Supreme Judicial Court affirmed the judgment of a single justice of the court dismissing as moot Petitioner's petition pursuant to Mass. Gen. Laws ch. 211, 3, holding that the single justice did not abuse her discretion. Petitioner was convicted of murder in the first degree and sentenced to life in prison. While he was still in prison, Petitioner filed his Mass. Gen. Laws ch. 211, 3 petition asking the Supreme Judicial Court to order his release because the Department of Correction allegedly failed in its duty to timely release him after granting him medical parole. While Petitioner's petition was pending, Petitioner was released. The single justice thereafter dismissed the petition as moot. The Supreme Judicial Court affirmed, holding that the single justice did not abuse her discretion in not addressing the substantive merits of Petitioner's petition. View "Vazquez v. Superintendent, Massachusetts Correctional Institution, Norfolk" on Justia Law

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The Supreme Judicial Court affirmed the decision of a single justice of the court denying Petitioner's petition pursuant to Mass. Gen. Laws ch. 211, 3 seeking review of a Housing Court judge's order denying his motion for waiver of an appeal bond, setting the bond, and ordering payment of use and occupancy during the pendency of Petitioner's appeal from an adverse summary process judgment, holding that the single justice neither erred nor abused her discretion. Petitioner sought and received review of the Housing Court judge's order from a single justice of the Appeals Court. In challenging the order, Petitioner neither appealed to the Appeals Court from the dismissal of his summary process appeal, nor did he raise his claims concerning the bond and the use and occupancy payments in the direct appeal from the summary process judgment in the Appeals Court. Because Petitioner had other adequate and effective routes to seek relief, the Supreme Judicial Court held that the single justice properly denied relief under Mass. Gen. Laws ch. 211, 3. View "Perry v. U.S. Bank Trust, N.A." on Justia Law

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The Supreme Judicial Court affirmed the decision of a single justice of the court treating Petitioner's requests for declaratory, injunctive, and other relief concerning certain inmate mail regulations as a petition pursuant to Mass. Gen. Laws ch. 211, 3 and denying relief, holding that the single justice neither erred nor abused her discretion. Specifically, the Supreme Judicial Court held (1) Petitioner's memorandum filed pursuant to S.J.C. Rule 2:21, as amended, did nothing to establish the inadequacy of the ordinary process of trial and appeal; and (2) the single justice acted within her discretion in concluding that there was no reason to exercise the court's extraordinary authority to grant the preliminary injunction or otherwise grant the relief requested by Petitioner in the first instance. View "Snell v. Superintendent, Massachusetts Correctional Institute, Shirley" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction for murder in the first degree on the theory of extreme atrocity or cruelty, holding that the trial court did not abuse its discretion in ruling that Defendant's statements made to his doctors before and after the murder regarding his mental health were not admissible for their truth. On appeal, Defendant argued that the trial judge erred in ruling that Defendant's statements to two doctors about his mental health were not admissible substantively and that the judge's instruction to the jury that they could not consider such statements for the truth of the matter was incorrect as a matter of law. The Supreme Judicial Court disagreed and affirmed, holding (1) the judge did not err in ruling that the statements Defendant made to the doctors were not admissible for the truth of the matter or in instructing the jury to that effect; and (2) there was no reason for the Court to exercise its authority under Mass. Gen. Laws ch. 278, 33E to grant a new trial or to reduce or set aside the verdict of murder in the first degree. View "Commonwealth v. Rodriguez" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the county court denying, without a hearing, the Commonwealth's petition for relief under Mass. Gen. Laws ch. 211, 3 from an order of the municipal court, holding that the single justice did not abuse his discretion in denying the Commonwealth's petition without reaching the merits. Defendant was charged with drug possession after a confidential informant, working under the direction of the police department, carried out three controlled purchases of a substance believed to be heroin. Under information obtained in these controlled purchases, the police obtained a warrant to search Defendant's apartment. The search led to Defendant's arrest. Defendant filed a motion for rewards and promises under Mass. R. Crim. P. 14(a)(1)(C) seeking information concerning the police department's dealings with the confidential informant. The judge allowed the motion in part, finding that the information was necessary to prepare a defense. The Commonwealth filed its Mass. Gen. Laws ch. 211, 3 petition. The single justice denied relief. The Supreme Judicial Court affirmed, holding that the Commonwealth did not show that the petition presented an exceptional circumstance requiring the exercise of the court's extraordinary superintendence power. View "Commonwealth v. Rodriguez" on Justia Law

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The Supreme Judicial Court affirmed the judgment of a single justice of the court dismissing John Doe's complaint for declaratory and injunctive relief, relief in the nature of mandamus, equitable relief, and extraordinary relief under Mass. Gen. Laws ch. 211, 3 seeking relief of the obligation to register with the Sex Offender Registry Board (Board), holding that the single justice did not err or abuse his discretion in denying relief. In denying Doe's request to be relieved of the obligation to register with the Board, the single justice noted that Doe had an adequate alternative avenue to obtain relief by way of a request to the Board to be terminated and to have an evidentiary hearing where he may be represented counsel. The Supreme Judicial Court affirmed, holding that the single justice properly denied relief. View "Doe, Sex Offender Registry Board No. 21634 v. Sex Offender Registry Board" on Justia Law

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The Supreme Judicial Court affirmed the judgment of a single justice of the court granting the Commonwealth's petition under Mass. Gen. Laws ch. 211, 3 and ordering that a certain superior court judge be recused from acting on Defendant's postjudgment motion to dismiss the indictments against him or for a new trial in his criminal case, holding that the single justice did not err or abuse her discretion. Defendant was convicted of murder in the first degree. The Supreme Judicial Court remanded the case for consideration of whether Defendant was prejudiced by trial counsel's potential conflicts of interest. On remand, Defendant moved to dismiss the indictments against him or for a new trial on the basis of Brady violations. The motion judge raised the question whether she could be impartial because the prosecutor had since been appointed as a superior cour judge and was now her judicial colleague. The Commonwealth subsequently filed a motion in support of recusal. The judge denied the motion, concluding that she could be fair and impartial. The Commonwealth filed a Mass. Gen. Laws ch. 211, 3 petition. A single justice allowed the petition. The Supreme Judicial Court affirmed, holding that the prudent and legally correct result under the circumstances was for the judge to recuse herself. View "Commonwealth v. Cousin" on Justia Law

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In this appeal challenging Appellant's classification before the Sex Offender Registry Board (Board) as a level three sex offender, the Supreme Judicial Court remanded the matter, holding that once a hearing examiner has allowed a motion for expert funds to a sex offender seeking a review hearing on his classification, expert testimony in a board hearing is admissible unless it is irrelevant, unreliable, or repetitive. After the Board notified Appellant of his duty to register Appellant requested his statutory right to a review of his classification by one of the Board's hearing examiners. Before the hearing, Appellant, who was indigent, moved for expert funds to hire an expert in forensic psychology and assessing sex offenders' risk of reoffense. The hearing examiner granted the motion but, during the hearing, significantly limited the expert's testimony. On appeal, the superior court affirmed. The Supreme Judicial Court remanded the matter to the Board for a new hearing at which Appellant's expert may testify as to any relevant, reliable, and nonrepetitive evidence, holding that the hearing examiner improperly limited the scope of Appellant's expert's testimony. View "Doe, Sex Offender Registry Board No. 234076 v. Sex Offender Registry Board" on Justia Law