Justia Criminal Law Opinion Summaries

The defendant was convicted of first-degree murder for the stabbing death of his ex-girlfriend, Kathryn Mauke. The defendant and the victim had dated on and off for several years, but the victim ended the relationship in December 2014. On February 11, 2015, the defendant left work early, walked to the victim's home, and stabbed her thirty-two times. The defendant's primary defense at trial was that he was not criminally responsible due to mental illness, which the jury rejected.The case was initially tried in the Superior Court, where the defendant was found guilty of first-degree murder on theories of deliberate premeditation and extreme atrocity or cruelty. The defendant filed a motion for a new trial, arguing that the testimony of two incarcerated informants was unreliable and that his trial counsel was ineffective. The motion was denied by the same judge who presided over the trial. The defendant then appealed both his conviction and the denial of his motion for a new trial.The Supreme Judicial Court of Massachusetts reviewed the case. The court held that the testimony of the two incarcerated informants was permissible and declined to create a new rule requiring reliability hearings for such testimony. However, the court mandated supplemental jury instructions for future cases involving incarcerated informants. The court also found that the defendant's trial counsel provided effective assistance and that the prosecutor's statements during closing arguments were proper. The court concluded that the defendant's sentence of life without parole was unconstitutional based on a recent decision, Commonwealth v. Mattis, and modified the sentence to allow for parole eligibility after thirty years. The court affirmed the conviction and the denial of the motion for a new trial. View "Commonwealth v. Lacrosse" on Justia Law

The defendant was charged with assault and battery on a family or household member and was detained pretrial. While awaiting trial, he made two recorded phone calls to his fiancée, the alleged victim, advising her not to cooperate with authorities. He suggested that if she did not testify, the case against him would weaken. The fiancée expressed concerns about losing her housing and custody of her children due to police and Department of Children and Families (DCF) involvement. The defendant reassured her that things would improve if she followed his advice.The case was initially heard in the Lynn Division of the District Court Department, where the defendant was found guilty of witness intimidation under G. L. c. 268, § 13B. The judge denied the defendant's motion for a required finding of not guilty. The defendant appealed, and the Appeals Court affirmed the conviction. The Supreme Judicial Court of Massachusetts granted further appellate review.The Supreme Judicial Court of Massachusetts reviewed whether the defendant's statements constituted an offer or promise of anything of value to dissuade his fiancée from testifying. The court found that the Commonwealth failed to prove beyond a reasonable doubt that the defendant's vague assurances about their relationship and the potential end of the DCF investigation constituted a bribe. The court noted that the defendant did not have the power to influence the DCF investigation and that his statements did not amount to a quid pro quo arrangement. Consequently, the court reversed the conviction, set aside the finding, and ordered that judgment be entered for the defendant. View "Commonwealth v. Bellard" on Justia Law

A juvenile was indicted as a youthful offender for unarmed carjacking, unarmed assault with intent to rob, and assault and battery on an elder. The charges stemmed from an incident where the juvenile, after escaping from a secure facility, attacked an elderly man and stole his car. The juvenile pleaded guilty and was sentenced to two years in a house of correction followed by five years of probation.The Juvenile Court initially sentenced the juvenile to a house of correction, but after multiple probation violations, including missing appointments and being involved in new offenses, the court sentenced him to State prison. The juvenile appealed the sentence, arguing it was unlawful and that the judge did not adequately consider his well-being and the impact of recent literature on juvenile brain development.The Supreme Judicial Court of Massachusetts reviewed the case. The court found that the juvenile's sentence was lawful under G. L. c. 119, § 58, which allows for adult sentences, including State prison, for youthful offenders. The court determined that the Juvenile Court judge had appropriately considered the juvenile's criminal history, noncompliance with probation, and the need for public safety. The court also concluded that the judge did not need to make specific written findings on the impact of juvenile brain development literature.Additionally, the Supreme Judicial Court held that the Appellate Division of the Superior Court is authorized to review sentences to State prison imposed by the Juvenile Court on youthful offenders. This ensures that youthful offenders have the same procedural safeguards as adult criminal defendants. The court affirmed the juvenile's sentence and allowed for the appeal to the Appellate Division. View "Commonwealth v. Y." on Justia Law

The juvenile in this case was on probation after being adjudicated as a youthful offender for breaking and entering a vehicle with intent to commit a felony. While on probation, he began experiencing severe mental health issues, including hallucinations and delusions, which led him to obtain a firearm illegally. His mother called the police, and he was found in possession of a loaded firearm without a license. This led to new criminal charges and a notice of probation violation for not obeying state laws.The Juvenile Court judge found that the juvenile violated his probation by possessing the firearm and revoked his probation, sentencing him to incarceration. The judge ruled that the defense of lack of criminal responsibility was not available in probation violation hearings but considered the juvenile's mental illness in determining the disposition. The juvenile appealed, arguing that due process requires allowing the defense of lack of criminal responsibility in probation violation hearings.The Supreme Judicial Court of Massachusetts reviewed the case and held that the affirmative defense of lack of criminal responsibility is not required in probation violation hearings. The court reasoned that the primary inquiry in such hearings is whether the probationer violated a condition of probation, not whether the probationer is criminally responsible. However, the court acknowledged that evidence of mental illness is relevant to determining whether a violation was willful and in deciding the appropriate disposition. The court affirmed the lower court's decision, finding no error in the judge's ruling or abuse of discretion in revoking the juvenile's probation and imposing a sentence of incarceration. View "Commonwealth v. Z." on Justia Law

The defendant was convicted of murder in the first degree, armed assault with intent to murder, and assault and battery by means of a dangerous weapon. The charges stemmed from his role as the getaway driver after a shooting in Charlestown, Boston, where two men in hooded sweatshirts shot Ryan Morrissey and Jamie Lawton outside a convenience store, killing Morrissey and seriously injuring Lawton. Witnesses saw the assailants flee on foot and enter a car driven by the defendant. The car was later identified as belonging to the defendant's mother.In the Superior Court, the defendant was tried jointly with two alleged assailants, Danilo Soto and Alexander Soto, who were acquitted by the jury. The defendant was found guilty on all charges. He appealed, arguing insufficient evidence to prove he was the driver and that he shared the assailants' lethal intent. He also challenged the trial judge's decisions on jury selection and the admissibility of expert testimony.The Supreme Judicial Court of Massachusetts reviewed the case. The court found sufficient evidence to establish that the defendant was the getaway driver. However, it concluded that there was insufficient evidence to prove that the defendant knew of or shared the assailants' lethal intent. The court emphasized that the evidence did not show the defendant knew the assailants were armed or intended to kill the victims. Consequently, the court reversed the defendant's convictions of murder in the first degree, armed assault with intent to murder, and assault and battery by means of a dangerous weapon, and remanded the case for entry of a required finding of not guilty. View "Commonwealth v. Baez" on Justia Law

The defendant was convicted of reckless endangerment of a child and witness intimidation after attacking her twelve-year-old son. The incident began with an argument about the son's dental braces, leading the defendant to contemplate suicide. The next morning, she attempted to kill her son by stabbing him in the neck and trying to drown him. The son managed to escape and tried to call 911, but the defendant took his phone and told the dispatcher everything was fine. The son eventually called the police, who found him injured and the defendant attempting to harm herself.The defendant was indicted on multiple charges, including assault and battery by means of a dangerous weapon and attempted murder. After a bench trial, the Superior Court judge found her not guilty by reason of mental illness for the assault and attempted murder charges but guilty of reckless endangerment and witness intimidation. She was sentenced to five years of probation with conditions, including no unsupervised contact with her children and GPS monitoring for two years. The defendant appealed, and the Supreme Judicial Court granted direct appellate review.The Supreme Judicial Court upheld the convictions, finding sufficient evidence that the defendant was criminally responsible for her actions after the attack. The court determined that the defendant understood the criminality of preventing her son from calling 911 and could conform her conduct to the law. The court also found the indictment for reckless endangerment was not impermissibly ambiguous and that the GPS monitoring condition of probation was reasonable. The court affirmed the convictions and the probation condition. View "Commonwealth v. Rezac" on Justia Law

The case involves the defendant, Maryann Russo, who was charged with animal cruelty under G. L. c. 272, § 77, for her treatment of her terminally ill fourteen-year-old cocker spaniel, Tipper. Russo brought Tipper to a veterinarian who recommended euthanasia due to Tipper's severe health issues, including a large necrotic mass, bed sores, and open wounds. Russo declined euthanasia, falsely stating she would take Tipper to another veterinarian, and instead took him home. The Animal Rescue League (ARL) later removed Tipper from Russo's care after the veterinarian reported her suspicions. Tipper was found in poor condition and was subsequently euthanized.In the Quincy Division of the District Court, a criminal complaint was issued against Russo in February 2021. Russo filed a motion to dismiss the complaint, arguing it lacked probable cause. The District Court judge granted the motion, concluding that the statute did not impose an affirmative obligation to euthanize an animal. The Commonwealth appealed, and the Appeals Court affirmed the dismissal, reasoning that the statute did not criminalize the failure to euthanize an animal. The Supreme Judicial Court granted further appellate review.The Supreme Judicial Court affirmed the dismissal, holding that the Commonwealth failed to establish probable cause that Russo acted with the requisite criminal intent. The court concluded that the statute required proof that Russo knowingly and willfully authorized or permitted Tipper to be subjected to unnecessary suffering. The court found that Russo's actions, including seeking medical care and attempting to make Tipper comfortable, did not indicate an intent to cause unnecessary suffering. The court emphasized that speculation alone was insufficient to establish probable cause. View "Commonwealth v. Russo" on Justia Law

The defendant was convicted of first-degree murder for the stabbing death of Jordan Baskin. After his conviction, the defendant filed a motion for a new trial, claiming his trial counsel provided ineffective assistance during a police interview where incriminating evidence was obtained. The defendant argued that his trial counsel failed to provide effective representation and had a conflict of interest because filing a motion to suppress the evidence would have been against her own interests.The Superior Court judge allowed the motion for a new trial, finding that the trial counsel had an actual conflict of interest and that the defendant did not waive this conflict knowingly and intelligently. The judge concluded that the conflict alone warranted a new trial without needing to show additional prejudice.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the lower court's decision. The court found that the trial counsel's personal interests materially interfered with her independent professional judgment, creating an actual conflict of interest. This conflict arose because the trial counsel's performance during the police interview was in question, and she could not provide detached advice or pursue a motion to suppress the evidence obtained during the interview zealously. The court also determined that the defendant did not validly waive this conflict, as the colloquies before trial did not address the specific conflict related to the adequacy of counsel's performance at the police interview. Therefore, the court affirmed the order for a new trial. View "Commonwealth v. Brown" on Justia Law

In November 2004, a sixteen-year-old juvenile stalked and robbed a victim at gunpoint, repeatedly raped her in her home, and then bound, gagged, and robbed her roommate when she arrived. He was sentenced to state prison for aggravated rape and other offenses, with a period of parole ineligibility compliant with constitutional requirements. After serving his prison term, he was placed on probation for the remaining nonhomicide offenses.In March 2007, the juvenile was adjudicated as a youthful offender and sentenced to sixteen to twenty years in state prison for aggravated rape, with additional concurrent and consecutive sentences for other offenses. In 2021, following a court decision, his sentence was restructured to comply with constitutional requirements, reducing his parole ineligibility to fifteen years. He was released from prison in January 2022 and began a five-year probation term. In August 2022, he was arrested for new offenses, leading to a probation violation notice and detention.The Supreme Judicial Court of Massachusetts reviewed the case. The court held that the restructured sentence, including the probation term, did not violate constitutional protections against cruel or unusual punishment. The court emphasized that the probation term provided the juvenile with an opportunity for rehabilitation and reintegration into the community. The court also noted that any potential further incarceration resulting from a probation violation would be subject to constitutional constraints, ensuring that the juvenile would not be treated more harshly than a juvenile convicted of murder for parole eligibility purposes. The court affirmed the order denying the juvenile's motion for relief from unlawful restraint. View "Commonwealth v. Sajid S." on Justia Law

The case revolves around the defendant, Mark O'Brien, who was convicted of first-degree murder for the killing of Robert McKenna. The murder occurred during a robbery scheme where O'Brien and his two co-venturers entered McKenna's home to steal marijuana, a firearm collection, and other valuables. The robbery turned violent when they found McKenna awake, leading to a struggle where they struck McKenna repeatedly in the head with a metal frying pan, causing his death. No DNA or other forensic evidence placed O'Brien at the scene, leading to his defense that he was not the third co-venturer.The Superior Court Department found and returned indictments against O'Brien on November 24, 2015. The cases were tried before Jeffrey A. Locke, J., and a motion for a new trial, filed on August 27, 2021, was heard by Mark A. Hallal, J. O'Brien was convicted of murder in the first degree and twelve other charges. He appealed his conviction and also filed a motion for a new trial, arguing that he received ineffective assistance of counsel because his trial counsel withdrew a request for an involuntary manslaughter jury instruction.The Supreme Judicial Court of Massachusetts reviewed the case and found no error in the lower court's proceedings. The court held that the defendant's counsel's decision to withdraw the request for an involuntary manslaughter instruction was not manifestly unreasonable given the evidence. The court also found no prosecutorial misconduct in the handling of the informant's testimony or the closing argument. However, the court vacated the defendant's convictions of unlawful possession of a firearm and remanded those charges for a new trial, in light of a recent Supreme Court decision requiring the prosecution to prove lack of licensure. The court affirmed the defendant's other convictions and the order denying his motion for a new trial. View "Commonwealth v. O'Brien" on Justia Law