Justia Criminal Law Opinion Summaries

The Supreme Judicial Court affirmed the judgment of the single justice denying, without a hearing, Appellant’s petition for relief under Mass. Gen. Laws ch. 211, 3, holding that the superior court judge properly denied Appellant release on his personal recognizance after finding that no conditions of release would reasonably assure the safety of persons in the community.Appellant was indicted for trafficking of a personal for sexual services, deriving support from prostitution, and witness intimidation. After a dangerousness hearing in the witness intimidation case, the judge ordered that Appellant be held without bail for a period of not more than 120 days. The judge also set bail in the sex trafficking cases at $20,000. Appellant later sought a bail hearing, but no bail hearing was held at that time. Appellant then filed this petition, without success. The Supreme Judicial Court affirmed the judgment denying relief, holding that Appellant failed to show that any of the judge’s factual findings were clearly erroneous or that the judge otherwise erred or abused his discretion. View "Garcia v. Commonwealth" on Justia Law

The Supreme Judicial Court vacated the district court denial of Defendant’s motion for a new trial after he pleaded guilty to violating multiple controlled substances laws, holding that remand was required for further proceedings on Defendant’s claim of ineffective assistance of counsel because the judge might have failed to recognize his discretion to credit or discredit Defendant’s affidavits as they pertained to plea counsel’s allegedly deficient performance and failed to make factual findings about whether special circumstances relevant to the prejudice inquiry existed.After Defendant entered his plea, he filed a motion for a new trial pursuant to Mass. R. Crim. P. 30(b), arguing that his counsel had rendered ineffective assistance and that he would not have pleaded guilty if counsel had properly advised him about the plea’s immigration consequences. The motion judge denied the motion after holding a nonevidentiary hearing. The Supreme Judicial Court vacated the denial of the motion for a new trial, holding that remand was required for findings relating to the issue of plea counsel’s deficient performance and the issue of special circumstances. View "Commonwealth v. Lys" on Justia Law

The Supreme Judicial Court dismissed as moot Petitioner’s appeal from a judgment of a single justice of the court denying his petition for relief pursuant to Mass. Gen. Laws ch. 211, 3, holding that the appeal was moot in the sense that the relief Petitioner sought could no longer be granted.Petitioner, an inmate, filed a complaint seeking review of an inmate disciplinary report against him. At issue was the denial of Petitioner’s motion to amend the complaint. A single justice of the Appeals Court denied Petitioner’s petition seeking interlocutory review of the superior court judge’s denial of the motion. Petitioner then filed a petition in the county court seeking relief from the superior court’s order. After the single justice denied relief, the underlying disciplinary report was dismissed and the guilty finding was expunged from Petitioner’s administrative record. The Supreme Judicial Court dismissed as moot Petitioner’s appeal from the judgment of the single justice because the relief Petitioner sought - leave to amend his complaint - could no longer be granted. View "Hudson v. Superintendent, Massachusetts Correctional Institution, Concord" on Justia Law

The Supreme Judicial Court affirmed the order of the motion judge allowing Defendant’s motion to suppress evidence discovered when police officers “froze” a house while they obtained a warrant, holding that the suppression order was proper because there was an insufficient basis to believe that evidence would be lost or destroyed.The court of appeals reversed the suppression order, concluding that the police officers’ actions were justified to prevent the removal or destruction of evidence. The Supreme Judicial Court disagreed, holding that that police officers were not justified in conducting a warrantless search to prevent the loss or destruction of evidence. View "Commonwealth v. Owens" on Justia Law

The Supreme Judicial Court affirmed Defendant’s convictions of first degree murder on theories of deliberate premeditation, extreme atrocity or cruelty, and felony-murder with armed home invasion and armed robbery as the predicate felonies and discerned no basis to exercise its authority under Mass. Gen. Laws ch. 278, 33E to reduce the degree of guilt or order a new trial, holding that there was no reversible error in the proceedings below.On appeal, Defendant claimed four instances of error in the admission of evidence and that the trial court erred in denying his motion for a new trial. The Supreme Judicial Court affirmed the judgments and declined to grant relief under Mass. Gen. Laws ch. 278, 33E, holding that the evidence of Defendant’s guilt in this case was overwhelming and there was no error requiring reversal. View "Commonwealth v. Moore" on Justia Law

The Supreme Judicial Court affirmed the judgment of a single justice of the Court denying, without a hearing, Appellant’s petition for relief under Mass. Gen. Laws ch. 211, 3 seeking review of the superior court judge’s orders on his motions filed in connection with his motion for a new trial, holding that the single justice neither erred nor abused his discretion in denying the petition.Appellant pleaded guilty to multiple counts of trafficking of a person for sexual servitude and other charges. Appellant subsequently filed a motion for a new trial, seeking to withdraw his pleas, and filed several additional motions in connection with that motion. A single justice denied the petition without a hearing. The Supreme Judicial Court affirmed, holding that where Petitioner had an adequate alternative avenue to seek review, his petition under Mass. Gen. Laws ch. 211, 3 was properly denied. View "Dew v. Commonwealth" on Justia Law

The Supreme Judicial Court reformulated ten reported questions regarding the scope and application of the due process obligations established in Nelson v. Colorado, 137 S. Ct. 1249, 1252 (2017), providing guidance to trial courts and litigants regarding the repayment of probation fees, restitution victim-witness assessments, forfeitures, fines, and court costs after a conviction has been invalidated.In Nelson, the United States Supreme Court held that when a criminal conviction is invalidated and no retrial will occur, the state is required under the Due Process Clause to refund fees, court costs, and restitution exacted from the defendant as a consequence of the conviction. In these cases, after Defendants’ convictions were dismissed with prejudice, Defendants moved for refunds of the money paid in forfeitures, probation fees, and other costs. The judges reported the matters and questions of law to the Appeals Court. The Supreme Judicial Court answered the reported questions and remanded the cases to the reporting courts for proceedings consistent with this opinion. View "Commonwealth v. Martinez" on Justia Law

The Supreme court affirmed Defendant’s conviction of murder in the first degree and the superior court’s 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 to exercise its authority under Mass. Gen. Laws ch. 278, 33E to reduce the degree of guilt or order a new trial.Specifically, the Court held (1) defense counsel provided constitutionally effective assistance; (2) Defendant’s due process rights were not violated by the Commonwealth’s failure to disclose purported cooperation agreements it had with witnesses; (3) there was no prejudicial error in the admission of evidence of injuries the child sustained; and (4) the prosecutor did not improperly vouch for the credibility of the victim’s mother in her closing argument. View "Commonwealth v. Goitia" on Justia Law

The Supreme Judicial Court affirmed the judgment of the county court dismissing as moot Petitioner’s complaint for relief in the nature of mandamus, holding that where Petitioner received the specific relief sought in his complaint, the complaint was properly dismissed as moot.Petitioner pleaded guilty to various offenses. Petitioner later filed two motions seeking to withdraw those guilty pleas. Thereafter, Petitioner filed a complaint in the county court seeking an order direction the superior court to take action on his motions. While the complaint was pending, a superior court judge denied both motions. Accordingly, a single justice of the Court dismissed the complaint as moot. The Supreme Judicial Court affirmed, holding that the complaint was properly dismissed as moot. View "Stacy v. Superior Court Department" on Justia Law

The Supreme Judicial Court affirmed the judgment of the county court denying, without a hearing, Petitioner’s petition for relief under Mass. Gen. Laws ch. 211, 3, holding that the single justice did not err or abuse his discretion in denying extraordinary relief.Petitioner, who charged with several motor vehicle offenses, filed a motion to dismiss the complaint on the ground that the police failed to file the citations in a timely manner. The motion was denied after an evidentiary hearing. Petitioner then filed this petition. The Supreme Judicial Court affirmed, holding that Petitioner did not meet his burden under S.J.C. Rule 2:21 of setting forth the reasons why relief could not adequately be obtained on appeal or by other available means. View "Quigley v. Commonwealth" on Justia Law