Justia Criminal Law Opinion Summaries

The Supreme Judicial Court reversed the decision of the superior court granting a new trial in this criminal case after concluding that the evidence was insufficient to support Defendant's murder conviction on a theory of joint venture felony-murder, holding that granting Defendant's motion for a new trial was error.Defendant was convicted of murder in the first degree, armed robbery, and kidnapping. The court of appeals affirmed. More than forty years later, Defendant filed a motion for a new trial on the murder indictment, arguing that the Commonwealth presented insufficient evidence for the felony-murder conviction. The superior court judge granted the motion. The Supreme Judicial Court reversed, holding (1) the motion judge had authority to consider the sufficiency of the evidence following the Supreme Judicial Court's 33E plenary review on direct appeal; but (2) Defendant was estopped from raising the claim that the evidence was insufficient for the jury to have found that Defendant was a joint venturer in the armed robbery. View "Commonwealth v. Watkins (No. 1)" 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.Petitioner was charged with solicitation to commit a crime stemming from an incident involving an informant that occurred while Petitioner was incarcerated. During the trial court proceedings, Petitioner filed two motions seeking discovery related to the informant and an evidentiary hearing to determine whether the Department of Correction was a third party. The trial court judge denied both motions. Petitioner then filed his Mass. Gen. Laws ch. 211, 3 petition asking the single justice to vacate the trial court's orders denying his discovery-related motions. The single justice denied the petition. The Supreme Judicial Court affirmed, holding that because Petitioner could seek review of any error in the normal appellate process the single justice properly denied relief. View "Quinones v. Commonwealth" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction for murder in the first degree with deliberate premeditation, holding that there was no reversible error in the proceedings below and no reason for this Court to exercise its authority under Mass. Gen. Laws ch. 278, 33E to reduce or set aside the verdict.Specifically, the Supreme Judicial Court held that the trial judge did not commit prejudicial error in (1) allowing the Commonwealth's peremptory challenges of two prospective jurors over Defendant's objections pursuant to Batson v. Kentucky, 476 U.S. 79 (1986), and Commonwealth v. Soares, 377 Mass. 461 (1979); (2) admitting a graphic autopsy photograph; and (3) allowing rebuttal testimony about overheard telephone statements of a Commonwealth witness imparting that she altered her testimony upon receipt of death threats and denying Defendant's request to conduct consequent voir dire of that witness. View "Commonwealth v. Jackson" on Justia Law

The Supreme Judicial Court affirmed the decision of the Sex Offender Registry Board ordering John Doe to register as a level three offender, holding that the Board's decision was not arbitrary or capricious and was supported by substantial evidence.On appeal, Doe argued that the Board should be required to prove new sex offenses by clear and convincing evidence and that the Board's decision was improper because it was not based on new information and the hearing was not held within a reasonable time. The Supreme Judicial Court disagreed, holding (1) subsidiary facts, including new sex offenses, need be proved by a preponderance of the evidence, and regardless, there was clear and convincing evidence supporting the level three upward reclassification; and (2) because the Board initiated the reclassification process shortly after receiving information of the new sex offense charges, and because the delays in reaching a final decision were not unreasonable, the Board's decision was proper. View "Doe v. Sex Offender Registry Board" on Justia Law

The Supreme Judicial Court held that "a first offense of a [minor] misdemeanor" in Mass. Gen. Laws ch. 119, 52 refers to a first episode of minor misdemeanor level misconduct.Four juveniles with no prior offenses were charged with several offenses, including several minor misdemeanors and a felony charge of inciting a riot, all arising from the same episode. A juvenile court judge dismissed the charges of inciting a riot against all three juveniles and decided not to immediately arraign on the minor misdemeanor charges. At issue was which of the charges constitutes a first offense of a minor misdemeanor pursuant to Mass. Gen. Laws ch. 119, 52. The Supreme Judicial Court held (1) all of the minor misdemeanors arising out of the single episode for each juvenile constituted a first offense for which the legislature intended a second change and must be dismissed, but the Commonwealth may proceed directly to arraignment on the greater offenses; (2) there was no probable cause to support the charge of inciting a riot; and (3) Mass. Gen. Laws ch. 264, 11 must be read consistently with the limitations in Brandenburg v. Ohio, 395 U.S. 444 (1969). View "Commonwealth v. Manolo M." 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 seeking relief from a superior court judge's order denying his motion to continue the third day of an evidentiary suppression hearing, holding that the single justice did not err or abuse his discretion.At issue before the single justice was whether the trial judge's directive to Petitioner to make a choice whether to appear for an evidentiary hearing in person or via video conference was sufficiently important and extraordinary as to warrant the exercise of the Supreme Judicial Court's extraordinary power pursuant to Mass. Gen. Laws ch. 211, 3. The Supreme Judicial Court held that the single justice did not err or abuse his discretion in denying Petitioner's petition. View "Malary v. Commonwealth" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions for murder in the first degree on the theory of felony murder and other crimes, holding that there was no prejudicial error in the proceedings below.Specifically, the Supreme Judicial Court held (1) several challenged statements made by the prosecutor in his closing argument did not constitute prejudicial error; (2) the trial judge did not err by denying Defendant's request for a voluntary manslaughter instruction based on self-defense, reasonable provocation, or sudden combat; and (3) this Court declines to exercise its authority under Mass. Gen. Laws ch. 278, 33E to reduce the verdict or order a new trial on the grounds that Defendant was only nineteen years old at the time of the murder. View "Commonwealth v. Tate" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions for murder in the first degree by deliberate premeditation and of unlawful possession of a firearm, holding that a new trial was not required because there was no error and that there was no reason for the Court to exercise its authority under Mass. Gen. Laws ch. 278, 33E to reduce the verdict of murder in the first degree.Specifically, the Supreme Judicial Court held (1) the trial judge did not err by declining to give a requested instruction on self-defense; (2) the trial judge did not abuse his discretion by allowing the prosecutor to introduce prior bad act evidence; (3) the prosecutor's remarks in her opening statement and closing argument did not create a substantial likelihood of a miscarriage of justice; (4) trial counsel provided constitutionally effective assistance; and (5) a new trial was not warranted based on purported newly discovered evidence. View "Commonwealth v. Teixeira" on Justia Law

The Supreme Judicial Court vacated the judgments entered against Defendant in this criminal case, holding that the trial judge abused his discretion in excusing a juror who claimed to be unable to begin deliberations anew after the discharge of another juror.A jury convicted Defendant of murder in the first first degree on a theory of felony murder, as well as assault and battery by means of a dangerous weapon causing serious bodily injury and possession of a firearm. On appeal, Defendant argued that the motion judge erred in denying his motion to suppress and that the trial judge erred in excusing a juror. The Supreme Judicial Court vacated the judgments entered against Defendant, holding (1) the trial court did not err in denying Defendant's motion to suppress; but (2) the trial court's discharge of the juror in question was error, and the error was prejudicial to Defendant. View "Commonwealth v. Williams" on Justia Law

The Supreme Judicial Court held that 120 Code Mass. Regs. 200.08(3)(c) (regulation), which concerns parole eligibility for inmates sentenced to a prison term that runs consecutive to a life sentence, is contrary to the plain terms of the statutory framework governing parole and is thus invalid.Plaintiffs, two inmates who were serving life sentences for murders committed when they were juveniles, sought declaratory relief invalidating the regulation. The superior court granted summary judgment in favor of the parole board, finding the regulation to be valid. The Supreme Judicial Court reversed, holding that by exempting sentences consecutive to a life sentence from the process often referred to as the "aggregation rule," the regulation contravenes the plain meaning of Mass. Gen. Laws ch. 127, 130 and 133. View "Dinkins v. Massachusetts Parole Board" on Justia Law