Justia Criminal Law Opinion Summaries

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

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

The Supreme Judicial Court affirmed Defendant's convictions of murder in the first degree and unlawful possession of a firearm, holding that Defendant's arguments on appeal were without merit.Specifically, the Supreme Judicial Court held (1) there was no abuse of discretion in the trial judge's determination that the defense had not established a prima facie case of racial discrimination in jury selection; (2) there was no prejudicial error in the jury instructions; (3) the judge did not abuse her discretion in excusing a juror based on decades-old charges; (4) the prosecutor did not commit misconduct in this case; and (5) there was no error or other reason warranting relief under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Grier" on Justia Law

The Supreme Judicial Court reversed the decision of the trial court convicting Defendant of operating a motor vehicle while under the influence of alcohol (OUI) and negligent operation of a motor vehicle, holding that the trial court erred in denying Defendant's motion to suppress.Defendant moved to suppress the results of a blood alcohol content (BAC) analysis conducted by a crime lab after the police obtained and executed a search warrant for Defendant's blood, arguing that he did not consent to having his blood tested. The trial judge denied the motion. The Supreme Judicial Court reversed, holding that, in a prosecution under 24(1)(a), where the Commonwealth wishes to have admitted BAC evidence arising from testing or analysis of a defendant's blood done "by or at the direction of" police, police must first obtain the defendant's consent to the "chemical test or analysis" of his blood that may result from such evidence, regardless of whomever first drew the blood. View "Commonwealth v. Moreau" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant, after a jury trial, of murder in the first degree on a theory of deliberate premeditation, holding that there was no reversible error in the proceedings below.Specifically, the Supreme Judicial Court held (1) the trial judge did not err in denying Defendant's motion for a mistrial; (2) in no instance did the admission of polygraph evidence constitute reversible error; (3) the trial judge did not err in denying Defendant's request for an instruction on voluntary manslaughter; and (4) this Court discerns no reason to exercise its authority under Mass. Gen. Laws ch. 278, 33E to order a new trial or reduce the degree of guilt. View "Commonwealth v. Gamboa" on Justia Law

The Supreme Judicial 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. 278, 33E to reduce the verdict to manslaughter or to order a new trial, holding that Defendant was not entitled to relief on his claims of error.Specifically, the Supreme Judicial Court held (1) the exclusion of Defendant's recorded interview statements with police as inadmissible hearsay did not violate his constitutional rights; (2) the trial judge erred in instructing counsel that attorney-conducted voir dire is limited to questions solely related to apparent bias and does not include the opportunity to elicit information that may help counsel exercise a peremptory challenge, but the error was harmless; (3) the admission of relationship-related text messages between Defendant and a former romantic partner was not an abuse of discretion; and (4) the Commonwealth's cross-examination of Defendant did not result in reversible error. View "Commonwealth v. Steeves" on Justia Law

The Supreme Judicial Court affirmed the judgment of the single justice of the court denying Appellants' petitions for relief in the county court pursuant to Mass. Gen. Laws ch. 211, 3 from the order of the municipal court that Appellants be detained on the ground of dangerousness, holding that there was no error. Appellants were charged with unlicensed firearm possession pursuant to Mass. Gen. Laws ch. 269, 10(a) and held before trial on the ground of dangerousness. On appeal, Appellants argued that including unlicensed firearm possession as a predicate offense violates substantive and procedural due process and that there was insufficient evidence of their dangerousness. The Supreme Judicial Court disagreed, holding (1) unlicensed possession of a firearm is a constitutional predicate offense under Mass. Gen. Laws ch. 276, 58A(1); and (2) there was no abuse of discretion in the determinations that Appellants should be held on the ground of dangerousness. View "Vega v. Commonwealth" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on theories of extreme cruelty and felony murder, holding that there was no error warranting a new trial, nor was there any reason to exercise the Court's extraordinary authority under Mass. Gen. Laws ch. 278, 33E to order a new trial or to reduce the degree of guilt.Specifically, the Supreme Judicial Court held (1) the evidence was sufficient to sustain Defendant's conviction of murder in the first degree on theories of extreme cruelty and felony murder; (2) although portions of the prosecutor's opening statement and examination of one witness were improper, the errors did not create a substantial likelihood of a miscarriage of justice; and (3) Defendant's challenges to the trial judge's evidentiary rulings were unavailing. View "Commonwealth v. Sun" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions of murder in the first degree, carrying a firearm without a license, and possession of a firearm without a firearm identification card, holding that there was no error warranting a new trial, nor was there any reason to exercise the Court's extraordinary authority under Mass. Gen. Laws ch. 278, 33E to order a new trial or to reduce the degree of guilt.Specifically, the Supreme Judicial Court held (1) the evidence was sufficient to support Defendant's murder conviction; (2) the prosecution's introduction of character and prior bad act evidence did not sufficiently influence the grand jury's decision to indict to require dismissal of the indictments; (3) there was no abuse of discretion in the judge's instruction on eyewitness identification; (4) the prosecutor's questions to the venire did not result in a biased jury; and (5) while several of the prosecutor's remarks during closing argument were improper, the improprieties did not warrant a new trial. View "Commonwealth v. Brown" on Justia Law

The Supreme Judicial Court vacated the opinion of a panel of the appeals court affirming the probation violation hearing judge's ruling that Probationer had violated the terms of his probation by committing new crimes, revoking his probation, and sentencing him to a term of incarceration, holding that Probationer's inability to question his accuser violated his right to present a defense.The hearing justice revoked Probationer's probation on the basis of hearsay statements by the complainant, his former fiancee, who alleged that Probationer had repeatedly raped her over a period of four months when they were living together. On appeal, Probationer argued that his constitutional due process rights were violated because the complainant did not appear at the hearing to testify or to be cross-examined. The Supreme Judicial Court agreed, holding that precluding Probationer from calling the accuser as a witness at the hearing violated Probationer's due process right to present a defense. View "Commonwealth v. Costa" on Justia Law