Justia Criminal Law Opinion Summaries

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 was indicted for assault and battery and, several months later, witness intimidation. The Commonwealth filed a motion to prohibit the two attorneys in the two cases from engaging in duplicative trial procedures. A superior court judge allowed the motion in large part. Petitioner’s petition challenged that order. The single justice denied relief on the ground that Petitioner had an adequate remedy in the normal appellate process. 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 "Gonsalves v. Commonwealth" 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 her discretion in denying extraordinary relief.Petitioner was indicted on charges of manslaughter and assault and battery. After a superior court denied Petitioner’s motion to produce a transcript of the instructions given to the grand jury, Petitioner filed this Mass. Gen. Laws ch. 211, 3 petition. The single justice denied relief on the ground that Petitioner had an adequate remedy in the normal appellate process. 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 be adequately obtained on appeal or by other available means. View "Robin v. Commonwealth" on Justia Law

The Supreme Judicial Court affirmed the judgment of a single justice of the Court denying Petitioner’s petition pursuant to Mass. Gen. Laws ch. 211, 3, holding that the single justice did not err or abuse his discretion in denying relief.In 2016, Petitioner pleaded guilty to drug-related crimes. Petitioner subsequently filed motions to withdraw his guilty pleas and for release from unlawful restraint, both of which were denied. Petitioner then filed this petition alleging that he had not received a fair hearing in the trial court on his motion for release from unlawful restraint and that he had received ineffective assistance of counsel. The single justice denied the petition without a hearing. The Supreme Judicial Court affirmed, holding that this case did not present the type of exceptional circumstance that requires the exercise of the Court’s extraordinary power of general superintendence pursuant to Mass. Gen. Laws ch. 211, 3. View "Perez-Acevedo v. Commonwealth" on Justia Law

The Supreme Judicial Court affirmed the judgment of a single justice of the Court denying Petitioner’s petition pursuant to Mass. Gen. Laws ch. 211, 3, holding that the single justice did not err or abuse his discretion in denying relief.In 1974, Petitioner was convicted of several crimes in two different cases. In 2014, Petitioner filed a motion for a new trial in each of the two cases. The trial court denied the motions, and the Appeals Court affirmed. Petitioner then filed this petition raising the same issues that he had raised in the Appeals Court. The single justice denied the petition without a hearing. The Supreme Judicial Court affirmed, holding that Petitioner was not entitled to review under Mass. Gen. Laws ch. 211, 3. View "McCants v. Commonwealth" on Justia Law

The Supreme Judicial Court affirmed the judgment of a single justice of the Court denying Petitioner’s petition pursuant to Mass. Gen. Laws ch. 211, 3, holding that the single justice did not err or abuse her discretion in denying relief.Petitioner was convicted of rape of a child and indecent assault and battery on a child under fourteen years of age. Petitioner later filed his Mass. Gen. Laws ch. 211, 3 petition alleging that the trial court ignored his motion to vacate, set aside, or correct sentence that he claimed to have previously filed. The single justice denied the petition without a hearing. The Supreme Judicial Court affirmed, holding that because it was unclear from the record whether the motion was actually ever received by and filed in the trial court Petitioner was not entitled to relief. View "Santos v. Commonwealth" on Justia Law

The Supreme Judicial Court held that the widespread evidence tampering of chemist Sonja Farak at the State Laboratory Institute in Amherst at the campus of the University of Massachusetts compromised the integrity of thousands of drug convictions and that her misconduct, compounded by prosecutorial misconduct, requires that the Court exercise its superintendence authority and vacate and dismiss all criminal convictions tainted by governmental wrongdoing.Farak stole and used for her own use drugs submitted to the lab for testing and consumed drug “standards” required for testing. Members of the Attorney General’s office deceptively withheld exculpatory evidence on the matter. Petitioners sought dismissal of thousands of cases tainted by governmental wrongdoing. The Supreme Judicial Court held that the class of “Farak defendants” includes all defendants who were found guilty of a drug charge where Farak signed the certificate of analysis, the conviction was based on methamphetamine and the drugs were tested during Farak’s tenure at the Amherst lab, or the drugs were tested at the Amherst lab during a certain period regardless of who signed the certificate of analysis. The Court also recommended that the standing advisory committee on the rules of criminal procedure propose amendments to Rule 14 of the Massachusetts Rules of Criminal Procedure to include a Brady checklist and any other beneficial modifications. View "Committee for Public Counsel Services v. Attorney General" on Justia Law

At issue was the correct interpretation of Mass. Gen. Laws ch. 279, 25(a), which requires that a “habitual criminal” - or an individual who has been convicted of a felony and has two prior convictions resulting in state or federal prison sentences of three years or more - be sentenced to the maximum term provided by law on the underlying conviction.Defendant was indictment of a variety of charges. All but two of the indictments carried sentencing enhancements under 25(a). The judge allowed Defendant’s motion to dismiss the section 25(a) sentence enhancement charges, concluding that Defendant’s predicate convictions represented a single “incident” under section 25(a). The Supreme Judicial Court overruled in part Commonwealth v. Pelletier, 449 Mass. 392, 395-396 (2007), holding (1) although the predicate convictions must arise from separate incidents or episodes, the offenses need not be separately prosecuted; and (2) Mass. R. Crim. P. 15(a)(1) and Mass. Gen. Laws ch. 278, 28E grant the Commonwealth a right to appeal from the dismissal of the sentence enhancement portion of an indictment. View "Commonwealth v. Ruiz" on Justia Law

The Supreme Judicial Court affirmed Defendant’s conviction of murder in the first degree, as a joint venturer, holding that none of the arguments Defendant raised on appeal warranted reversal of his convictions.During trial, the Commonwealth proceeded on a theory of felony-murder, with armed home invasion and attempted armed robbery as the predicate felonies. The Supreme Judicial Court affirmed Defendant’s convictions and declined to exercise its authority to grant relief under Mass. Gen. Laws ch. 278, 33E, holding (1) the evidence was sufficient to support the convictions; (2) the trial judge did not abuse her discretion in allowing cell site location information evidence; (3) the judge did not err when she did not instruct the jury that they were allowed to reach factually inconsistent verdicts; and (4) this Court declines to abolish the common-law doctrine of felony-murder. View "Commonwealth v. Bin" on Justia Law

The Supreme Judicial Court reversed the trial court’s order suppressing statements that Defendant made during custodial interrogations and suppressing the results of the forensic testing of Defendant’s bloodstained clothing, holding (1) a remand was necessary to determine whether the suppression of Defendant’s statements was proper; and (2) the police lawfully seized Defendant’s clothing incident to arrest and did not need a separate warrant to test the clothing for the presence of human blood.Defendant was charged with murder in the first degree in connection with the beating death of a woman who had obtained a restraining order against him. The motion judge determined that Defendant was too intoxicated during custodial interviews to make a knowing, intelligent, and voluntary Miranda waiver. The Supreme Judicial Court disagreed, holding (1) a remand was necessary for the trial judge to make findings and credibility determinations regarding all pertinent evidence in light of this Court’s de novo assessment of the recording of Defendant’s second custodial interview; and (2) the order suppressing the results of the forensic testing of Defendant’s clothing must be reversed. View "Commonwealth v. Tremblay" on Justia Law

The Supreme Judicial Court vacated Defendant’s conviction of murder in the first degree on the theory of deliberate premeditation, holding that the judge erred by declining to require an explanation for the prosecutor’s preemptory challenge to a female African-American member of the venire and erred in declining to give Defendant’s requested jury instructions on self-defense and voluntary manslaughter.The shooting that led to the fatality in this case was precipitated by a drug turf war. At the close of the evidence Defendant requested that the jury be instructed on self-defense and voluntary manslaughter, but the request was denied. The Supreme Judicial Court reversed, holding (1) the trial judge abused her discretion by declining to require the prosecutor to provide and adequate and genuine race-neutral reason for Defendant’s peremptory challenge to the juror at issue; and (2) considered in the light most favorable to Defendant, the evidence warranted instructions on self-defense and voluntary manslaughter based on the theory of excessive use of force in self-defense. View "Commonwealth v. Ortega" on Justia Law