Justia Criminal Law Opinion Summaries

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree and declined to grant extraordinary relief pursuant to Mass. Gen. Laws ch. 278, 33E but reversed the order denying Defendant's motion for third-party discovery and vacated the orders denying Defendant's motions for a new trial, holding that Defendant's motion for third-party discovery should have been allowed and that denying Defendant's motions for a new trial without first conducting an evidentiary hearing was error.The Supreme Court remanded this case to the superior court to allow Defendant to conduct the requested third-party discovery of e-mail service providers to determine whether additional e-mail messages between the victim and a third-party culprit existed. The Court noted that Defendant may amend his second motion for a new trial to include any information obtained as a result of the discovery requests. View "Commonwealth v. Holbrook" on Justia Law

The Supreme Judicial Court vacated three of the indictments in this case for a new trial, holding that the trial judge improperly failed to include certain language from paragraph three of Mass. Gen. Laws ch. 272, 105(b), in the instruction to the jury on the charges of secretly videotaping children but that paragraph three is not unconstitutionally vague.Defendant was convicted on ten indictments charging him with secreting videotaping unsuspecting individual adults who were nude or partially nude, in violation of Mass. Gen. Laws ch. 272, 105(b), paragraph one. Defendant was also convicted on five indictments charging violation of paragraph three of the statute for secretly videotaping children during the same incident. In a posttrial decision, the trial judge declared that paragraph three of the statute was unconstitutionally vague and vacated Defendant's convictions of videotaping the children. The Supreme Court remanded for a new trial three of the five convictions for videotaping the children, holding (1) the proper unit of prosecution under section 105(b), first paragraph, is based on the individual victims; and (2) section 105(b), third paragraph, is not unconstitutionally vague, but the trial judge improperly instructed the jury on these charges. View "Commonwealth v. Wassilie" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions and the denial of his motion for a new trial, holding that there was no reversible error in the proceedings below and that there was no reason for this Court to exercise its authority under Mass. Gen. Laws ch. 237, 33E to grant a new trial or to either reduce or set aside the verdict of murder in the first degree.Defendant was convicted of murder in the first degree on the theory of deliberate premeditation. The Supreme Court affirmed Defendant's convictions and the trial court's denial of his motion for a new trial, holding (1) the motion judge did not err in denying Defendant's motion to suppress the cell site location information used by the Commonwealth in this case; (2) no other reversible error occurred in this case; and (3) reversal was not warranted due to cumulative error. View "Commonwealth v. Hobbs" on Justia Law

The Supreme Judicial Court held that interference with the lawful duties of a police officer is a common-law crime in Massachusetts but that the evidence was not sufficient in this case to establish that Defendant committed the crime of interference with a police officer.A jury convicted Defendant of interference with a police officer. At issue on appeal was whether the crime of which Defendant was convicted is recognized under Massachusetts common law. After examining Nineteenth Century jurisprudence, as well as other authoritative sources, the Supreme Judicial Court held that interference with the lawful duties of a police officer was, and continues to be, a common-law crime subject to carefully constructed limitations to avoid criminalizing constitutionally protected activities. The Court, however, vacated Defendant's conviction, holding that the evidence was insufficient to sustain the conviction of interference with a police officer. View "Commonwealth v. Adams" on Justia Law

The Supreme Court vacated the judgments entered against Defendant and remanded this case for further proceedings, holding that the dismissal of a juror was prejudicial error and that there was sufficient evidence to survive Defendant's motion for required findings of not guilty.A jury found Defendant guilty of multiple charges relating to the illegal possession and improper storage of firearms and ammunition. During deliberations, a juror informed a court officer that she could not continue to deliberate. After a colloquy with the juror, the judge discharged the deliberating juror and replaced her with an alternate juror. Ninety minutes later, the jury found Defendant guilty. The Appeals Court affirmed. The Supreme Court vacated Defendant's convictions, holding (1) the juror was discharged for reasons that were not purely personal to the juror, and her dismissal was prejudicial error; and (2) the trial judge did not err in denying Defendant's motion for required findings of not guilty. View "Commonwealth v. Tiscione" on Justia Law

The Supreme Judicial Court vacated and set aside Defendant's convictions for murder in the first degree, armed assault with intent to murder, and firearm offenses, holding that four trial errors required that the verdicts be vacated and set aside and this matter remanded to the superior court for a new trial.Specifically, the Supreme Judicial Court held (1) the trial court erred in admitting a coventurer's statements against Defendant under the joint venture exemption to the hearsay rule, and admission of the statements was barred by the Sixth Amendment; (2) the trial court erred in admitting the opinion of the Commonwealth's gang expert, and the error was prejudicial; (3) the trial court erred in allowing police witnesses to give their opinions as to the identity of individuals depicted in surveillance footage; and (4) the prosecutor engaged in impermissible argument during closing, and a new trial was required. View "Commonwealth v. Wardsworth" on Justia Law

In this case involving Defendant's failure to properly install child safety seats in her vehicle, the Supreme Judicial Court vacated Defendant's convictions of involuntary manslaughter and reckless endangerment as to Dylan Riel but affirmed Defendant's two convictions of negligent homicide, holding that there was insufficient evidence to show that Defendant's conduct was wanton or reckless.Defendant was involved in a multi-vehicle accident in which her two nephews - four-year-old Dylan Riel and and sixteen-month-old Jayce Garcia - were fatally injured. At the time of the accident Dylan was seated in the backseat of Defendant's sedan with a seat belt fastened but without an age and size appropriate child safety booster seat. Jayce was in a front-facing safety seat with the straps set too high rather than an age and size appropriate rear-facing safety seat. Defendant was convicted of manslaughter of Dylan, reckless endangerment of Dylan, and negligent motor vehicle homicide of Dylan and Jayce. The Supreme Court reversed the judgments of conviction of manslaughter and reckless endangerment of a child and otherwise affirmed, holding that there was not legally sufficient evidence to show Defendant's conduct was wanton or reckless. View "Commonwealth v. Hardy" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on theories of deliberate premeditation and extreme atrocity or cruelty, holding that there was no reversible error nor a reason to exercise its authority under Mass. Gen. Laws ch. 278, 33E to either reduce Defendant's convictions or grant a new trial.Specifically, the Court held (1) the trial judge did not err in declining to instruct the jury on voluntary manslaughter; (2) Defendant's age at the time of his crimes - nineteen years old - did not render his sentence of life imprisonment without the possibility of parole unconstitutional; and (3) the trial judge did not clearly err in refusing to grant a new trial due to a partial courtroom closure. View "Commonwealth v. Garcia" on Justia Law

The Supreme Judicial Court reversed the judgment of conviction in this case as to negligent operation and affirmed the judgment of conviction of operating a motor vehicle while under the influence, holding that the evidence was insufficient to support Defendant's conviction of negligent operation.On appeal, Defendant argued, among other things, that the trial judge erred in denying his motion for a required finding of not guilty because the evidence was insufficient to support the convictions. The Appeals Court affirmed Defendant's convictions. The Supreme Judicial Court reversed in part, holding that, under the circumstances of this case, the evidence was insufficient to warrant a finding that Defendant actually operated his vehicle in such a way as to endanger the lives or safety of the public when there was no other evidence of negligent operation. View "Commonwealth v. Zagwyn" on Justia Law

The Supreme Judicial Court affirmed Defendant's sentence of three consecutive terms of life imprisonment, with the possibility of parole after forty-five years, in connection with his conviction of three counts of murder in the first degree, holding that the sentence was within constitutional bounds.Defendant was a juvenile homicide offender and sought resentencing when he was well into adulthood. After the Supreme Judicial Court decided Commonwealth v. Costa, 472 Mass. 139 (2015), the Commonwealth conceded that Defendant was entitled to a resentencing hearing. After a hearing, the sentencing judge reinstated Defendant's sentence. Defendant then filed an application with the Supreme Court pursuant to Mass. Gen. Laws ch. 278, 33E for leave to appeal from the resentencing judge's ruling, as well as a motion for direct entry of the appeal. The single justice directed entry of the appeal on the question of whether a juvenile homicide offender may be required to serve forty-five years in prison before his first opportunity to seek release based on rehabilitation. The Supreme Judicial Court held that Defendant's sentence did not constitute cruel or unusual punishment in violation of article 26 of the Massachusetts Declaration of Rights. View "Commonwealth v. LaPlante" on Justia Law