Justia Criminal Law Opinion Summaries

The Supreme Judicial Court affirmed the judgment of a single justice of the court denying Petitioner's petitions filed pursuant to Mass. Gen. Laws ch. 211, 3 and associated motions, holding that Petitioner was not entitled to extraordinary relief to correct errors that may be reviewed in the ordinary process of trial and appeal.Petitioner, who was indicted for rape and other charges and found incompetent to stand trial, was later determined to be competent to stand trial, and the proceedings were ongoing. In the petitions at issue, Petitioner made very general claims. The single justice declined to reach the merits of the petitions and denied relief. The Supreme Judicial Court affirmed, holding (1) the single justice did not err in denying the petitions; and (2) because this is the third time Petitioner sought extraordinary relief arising from the same criminal proceedings, Petitioner was on notice that further attempts to obtain such relief may result in the imposition of sanctions. View "Ardaneh v. Commonwealth" on Justia Law

The Supreme Judicial Court affirmed the order of a single justice of the court denying the Commonwealth's petition asking that the single justice reverse a superior court judge's order granting Defendant limited access to the alleged victim's apartment in order to prepare for trial, holding that there was no error.Defendant was charged with attempted murder and other crimes stemming from allegations that he strangled and beat the alleged victim in their shared apartment. After Defendant was provided with preliminary discovery including photographs of the alleged victim's apartment Defendant moved for access to the crime scene for defense counsel to capture additional details. The superior court judge allowed the motion, but the alleged victim denied access to certain rooms. Thereafter, the motion judge granted Defendant access to all rooms of the apartment under certain conditions. The Commonwealth then filed a petition under Mass. Gen. Laws ch. 211, 3 seeking reversal of the grant of Defendant's second motion. The single justice denied the petition. The Supreme Judicial Court affirmed, holding that there was no abuse of discretion or error of law in the denial of the Commonwealth's petition. View "Commonwealth v. Pond" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court denying Defendant's motion for a new trial following his successful motion for postconviction forensic and deoxyribonucleic acid (DNA) analysis pursuant to Mass. Gen. Laws ch. 278A, 2, holding that there was no error in the denial of Defendant's motion for a new trial.A jury convicted Defendant of murder in the first degree on a theory of extreme cruelty or atrocity, and the Supreme Court affirmed. Following multiple pro se motions, Defendant filed the instant motion for postconviction DNA analysis, which the court allowed. Defendant then filed a motion for a new trial. The motion judge denied the motion, concluding that the new evidence did not case real doubt on the justice of Defendant's conviction. Defendant then filed a petition pursuant to Mass. Gen. Laws ch. 278, 33E for leave to appeal. A single justice granted the petition. The Supreme Judicial Court affirmed the denial of Defendant's motion for a new trial, holding that Defendant was not entitled to relief on his allegations of error. View "Commonwealth v. Duguay" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions other than his unlawful possession conviction, which the Court vacated in light of its recent opinion in Commonwealth v. Guardado, 491 Mass. 666 (2023), holding that Defendant's rights under the Second Amendment and his due process rights were violated as to this conviction because the jury was not instructed that licensure was an essential element of the crime.Specifically, the Supreme Judicial Court held (1) the trial court did not err in denying Defendant's motion to suppress his statement at the police station on the grounds that police officers impermissibly recorded it without his express consent and that he was not informed promptly of his right to make a telephone call; (2) the prosecutor did not improperly refer to omissions in Defendant's statement to police officers; (3) there was no reason to reduce the degree of guilt or order a new trial; and (4) in light of this Court's recent opinion in Guardado, Defendant's unlawful possession of a firearm conviction must be vacated. View "Commonwealth v. Morris" on Justia Law

The Supreme Judicial Court affirmed in part and vacated in part Defendant's convictions, holding that Defendant's convictions on three charges of assault by means of a dangerous weapon were duplicative.Specifically, the Supreme Judicial Court held (1) the trial court did not err in denying Defendant's motion for a new trial, motion for an evidentiary hearing, and motion for further discovery; (2) there was no prejudicial error in Defendant's convictions of murder in the first degree, three charges of armed assault with intent to commit murder, and carrying a firearm without a license; (3) Defendant's three convictions of assault by means of a dangerous weapon were duplicative of his three convictions of armed assault with intent to murder; and (4) Defendant was not entitled to relief on his remaining allegations of error; and there was no reason to grant extraordinary relief under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Fernandes" on Justia Law

The Supreme Judicial Court affirmed the order of the trial judge reducing Defendant's conviction of murder in the first degree to involuntary manslaughter pursuant to Mass. R. Crim. P. 25(b)(2), as amended, holding that the judge did not abuse her discretion by reducing the jury's verdict.Defendant was convicted of murder in the second degree on a theory of felony-murder with arson as the predicate felony. Defendant later filed this rule 23(b)(2) motion. The judge granted the motion and reduced Defendant's conviction, concluding that the weight of the evidence showed that Defendant lacked the requisite intent and also taking into account mitigating circumstances constituted by Defendant's cognitive limitations and mental disorder. The Supreme Judicial Court affirmed, holding that the reduction in Defendant's verdict was not an abuse of discretion. View "Commonwealth v. Pfeiffer" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions for murder in the first degree for the killing of Brandy Waryasz on theories of premeditation and felony-murder and murder in the first degree for the killing of Dane Anthony Hall, on a theory of felony-murder, but reversed his conviction for armed robbery, holding that the conviction must be dismissed as duplicative of the felony-murder conviction.Defendant attacked Waryasz while she was working at a gas station by tightly wrapping a ligature around her neck. Waryasz, who was seven months pregnant with Hall, died from a constricted airflow, killing her son within minutes of his mother. Defendant was indicted for two murders and armed robbery and convicted on all charges. Defendant later filed a motion for a new trial, which the superior court denied. The Supreme Judicial Court affirmed Defendant's convictions of murder in the first degree but vacated and set aside the armed robbery conviction, holding (1) as to Defendant's murder convictions, he was not entitled to relief on his allegations of error, and there was no ground for granting relief pursuant to Mass. Gen. Laws ch. 278, 33E; and (2) the armed robbery conviction was duplicative of the felony-murder conviction for the killing of Hall and therefore must be dismissed. View "Commonwealth v. Bateman" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions for deliberately premeditated murder in the first degree and unlawful possession of a firearm and declined to exercise its authority to grant extraordinary relief, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued that the trial judge erred in excluding evidence that law enforcement officers found illegal narcotics in a vehicle occupied by the victim and in the victim's clothing and that the judge's ruling "deprived the defense of the plausible alternative theory that rival drug dealers committed the murder." The Supreme Judicial Court disagreed and affirmed, holding (1) there was no evidentiary error in the proceedings below; (2) as to the firearm conviction, the trial court's failure to instruct the jury on licensure requirements was harmless beyond a reasonable doubt; and (3) the verdict of murder in the first degree was consonant with justice and should stand. View "Commonwealth v. Bookman" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of deliberately premeditated murder in the first degree and unlawful possession of a firearm and declined to exercise its extraordinary authority pursuant to Mass. Gen. Laws ch. 278, 33E to grant his a new trial or to reduce his first-degree murder conviction to a lesser degree of guilt, holding that there was no error or reason to disturb the verdicts.Together with his codefendant, Defendant was convicted of murder in the first degree on a theory of deliberate premeditation. Defendant, who was also convicted of unlawful possession of a firearm, appealed, arguing, among other things, that the trial judge erroneously excluded evidence that supported a third-party culprit defense. The Supreme Judicial Court affirmed, holding (1) the trial judge's exclusion of certain evidence did not deprive the defense "of the plausible alternative theory that rival drug dealers were responsible for the murder"; (2) there was no abuse of discretion in allowing introduction of testimony that the codefendant possessed a firearm eight months before the shooting; and (3) there was no reason to order a new trial or to reduce the degree of guilt as to the conviction of murder in the first degree. View "Commonwealth v. Acevedo" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction for murder in the first degree on the theories of deliberate premeditation and extreme atrocity or cruelty and sentence of life without parole, holding that Defendant was not entitled to relief on his allegations of error and that there was no reason to grant relief under Mass. Gen. Laws ch. 278, 33E.Specifically, the Supreme Judicial Court held (1) the motion judge did not err in denying Defendant's motion to suppress evidence from the police officers who arrested him; (2) the trial judge did not err in denying Defendant's request for a mental impairment jury instruction; (3) testimony by the Commonwealth's fingerprint analysis expert was not improper; and (4) this Court discerns no reason to grant relief under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Armstrong" on Justia Law