Justia Criminal Law Opinion Summaries

The case involves Terrence Tyler, who was convicted of felony-murder in the first degree with the predicate felony of attempted unarmed robbery and assault with intent to rob. The incident occurred during a planned robbery of a marijuana dealer, Wilner Parisse, who was shot and killed during a physical altercation. Tyler appealed his conviction and filed two motions for a new trial. The first motion argued that his trial counsel was ineffective for not requesting an involuntary manslaughter jury instruction. The second motion requested the retroactive application of a court decision (Commonwealth v. Brown) that abolished felony-murder as an independent theory of liability for murder. Both motions were denied.The Supreme Judicial Court of Massachusetts reviewed Tyler's case and his motions for a new trial. The court held that the rule in Brown was intended to apply prospectively, and there was no reason to depart from that limitation. The court also found that Tyler's trial counsel did not err by failing to request an involuntary manslaughter instruction, as the pre-Brown default rule applies here. The court further held that the trial judge's instruction did not allow the jury to find Tyler guilty of felony-murder for conduct only sufficient to convict him of manslaughter. The court declined to reduce the verdict of murder in the first degree to a lesser degree of guilt. Therefore, Tyler's conviction was affirmed, and the orders denying his motions for a new trial were also affirmed. View "Commonwealth v. Tyler" on Justia Law

The Supreme Judicial Court of Massachusetts heard an appeal involving Bradley Zucchino, who was charged with operating a motor vehicle under the influence of alcohol, causing serious bodily injury and death. Zucchino challenged the admissibility of his blood alcohol content (BAC) evidence, arguing that it was collected without his consent, contravening G. L. c. 90, § 24 (1) (e). The court had to determine whether the Commonwealth needed the defendant's consent to admit his BAC results in the prosecution of a G. L. c. 90, § 24L (OUI-SBI) offense.The court determined that the language of G. L. c. 90, § 24 (1) (e) was clear and unambiguous, applying specifically to violations of § 24 (1) (a), or simple OUI. The court noted that if the Legislature had intended the consent requirement of § 24 (1) (e) to apply to aggravated OUI offenses, it would have made this explicit. The court stated that it is within the Legislature's purview to treat simple OUI and aggravated OUI offenses differently, including with regard to the admissibility of evidence.Therefore, the Supreme Judicial Court of Massachusetts held that the consent provision of § 24 (1) (e) does not apply to violations under any other section or chapter, including G. L. c. 265, § 13 1/2, or G. L. c. 90, § 24L. The court affirmed the lower court's denial of Zucchino's motion to suppress his BAC results. View "Commonwealth v. Zucchino" on Justia Law

Charles Robinson, the defendant, was convicted of first-degree murder in connection with the shooting death of Edward Figueroa. Following his conviction, Robinson appealed and also filed a motion for a new trial citing multiple errors by trial counsel. Despite his appeal and the motion for a new trial, the conviction was affirmed.Later, Robinson appealed from the denial of his motion for a new trial, arguing that he was not competent to stand trial due to mental health issues and that he had received ineffective assistance of counsel. However, the court upheld the ruling, stating that Robinson had not shown any evidence that his mental health issues had influenced the jury's conclusion or prevented an adequate defense.Robinson's contention that his counsel failed "reasonably to communicate with him" during and after a conversation in the lockup was also dismissed, as the court found no evidence of a breakdown in the attorney-client relationship that warranted a new trial.The court concluded that the defendant did not present a substantial issue meriting an evidentiary hearing and dismissed his request for relief under G. L. c. 278, § 33E for a new trial. View "Commonwealth v. Robinson" on Justia Law

In this case, the defendant, Rigoberto Escobar, was found guilty of first-degree murder for the shooting death of Magno Sosa after a heated argument that escalated into a fistfight. The defendant appealed, arguing that his confession to police was improperly obtained because he was improperly Mirandized, coerced into confessing, and his rights to prompt arraignment and telephone use after arrest were violated. Moreover, the defendant contended that the trial judge made errors by denying his motion for a mistrial and failing to instruct the jury on voluntary and involuntary manslaughter. He also claimed that improper testimony by the Commonwealth's experts on fingerprint identification and forensic ballistics led to a substantial likelihood of a miscarriage of justice. Lastly, the defendant argued that his firearm convictions should be vacated according to a recent ruling in Commonwealth v. Guardado.The Supreme Judicial Court of Massachusetts affirmed the defendant's conviction of murder in the first degree. They concluded that the defendant's motion to suppress his confession was properly denied, his motion for a mistrial was rightly denied, and the trial judge did not err in declining to provide a jury instruction on involuntary manslaughter. However, the trial judge did err in declining to instruct the jury on voluntary manslaughter. Despite this, they found the defendant was not prejudiced by this decision due to the jury instructions as a whole and the lack of evidence supporting a finding of voluntary manslaughter.The court also affirmed that even if the expert testimony was improper, it did not create a substantial likelihood of a miscarriage of justice because the Commonwealth presented overwhelming evidence tying the defendant to the firearm and to the crime. However, the court vacated the defendant's firearm convictions and remanded for a new trial to give the Commonwealth the opportunity to prove that the defendant was not licensed to carry a firearm. View "Commonwealth v. Escobar" on Justia Law

This case involved defendant Julie A. Corey who was convicted of first-degree murder on the grounds of deliberate premeditation, extreme atrocity or cruelty, and felony-murder with the underlying felony of aggravated kidnapping. Following her conviction, Corey filed a motion for a new trial, arguing that she received ineffective assistance of counsel due to her attorney's failure to call a cell phone expert to testify about her location on the night of the murder. She also requested that the court enter a required finding of not guilty. The trial judge, who was also the motion judge, denied Corey's motion for a new trial but vacated her conviction of murder in the first degree on a theory of felony-murder, finding that the evidence was insufficient to prove that Corey committed the predicate felony of aggravated kidnapping.On appeal, the Supreme Judicial Court disagreed with Corey’s argument that she received ineffective assistance of counsel. The court found that her trial counsel's decision not to call a cell phone expert was not ineffective and would not have likely influenced the jury's conclusions. Furthermore, the court agreed with the Commonwealth that there was sufficient evidence to find Corey guilty of felony-murder with a predicate felony of aggravated kidnapping. Consequently, the court reinstated that conviction. The court also declined to exercise its powers under G. L. c. 278, § 33E to reduce Corey's conviction. View "Commonwealth v. Corey" on Justia Law

The case revolves around a defendant convicted of severe, racially motivated violence, who sought to stay the execution of his sentence pending appeal. The defendant, a dual citizen of the U.S. and Morocco, with frequent travel to Morocco, was deemed a flight risk and a danger to others by the trial judge and a single justice of the Appeals Court. While the defendant demonstrated a likelihood of success on his appeal, the single justice upheld the trial judge's decision, citing the defendant's regular travels abroad, the serious nature of his crimes, and the significant sentence he faced as reasons for his potential flight risk. Following the denial of his stay, the defendant appealed to the Supreme Judicial Court of Massachusetts.The Supreme Judicial Court affirmed the lower courts' decisions. The court found that the defendant's likelihood of success on appeal did not mitigate the identified security risk. The court ruled that the likelihood of success on appeal and the potential security risk are two distinct factors to consider, and one does not influence the other. The court concluded that the single justice's decision was not outside the range of reasonable alternatives, thus not an abuse of discretion. Therefore, the Supreme Judicial Court upheld the denial of the defendant's motion to stay his sentence pending appeal. View "Commonwealth v. Kalila" on Justia Law

In the case of Commonwealth v. Rashad Shepherd, the Supreme Judicial Court of Massachusetts affirmed the defendant’s conviction of murder in the first degree on the theory of felony-murder, with attempted unarmed robbery as the predicate felony. The case centered around a failed robbery attempt that ended in the shooting and death of the intended victim. The defendant, along with two co-conspirators, hatched a plan to rob the victim, who was known to sell marijuana from his apartment. However, when the plan was put into motion, the victim resisted, and in the ensuing altercation, was shot and killed. The prosecution's theory was that the defendant was the shooter.In his appeal, the defendant argued that the court’s decision in a prior case, Commonwealth v. Brown, which abolished felony-murder as an independent theory of liability for murder in the first and second degrees, should be applied to his case retroactively. He maintained that not doing so violated equal protection principles as more Black individuals were serving life sentences without parole for felony-murder than white individuals. However, the court rejected this argument, noting that the decision in Brown was applied to all equally, regardless of race or ethnicity.The defendant also claimed errors in jury instructions and conduct by the trial judge, but the court determined that there was no reversible error. Lastly, the defendant argued that he received ineffective assistance of counsel, but the court found that the decisions by the defense were not manifestly unreasonable. View "Commonwealth v. Shepherd" on Justia Law

In the case before the Supreme Judicial Court of Massachusetts, the defendant, William J. Camuti, was convicted of murder in the first degree for poisoning his friend and business associate, Stephen Rakes, with potassium cyanide. Several years after his conviction, Camuti filed a postconviction motion for forensic testing of the shirt that Rakes was wearing when his body was found, claiming that DNA testing of the shirt could potentially provide evidence that could exonerate him. However, a Superior Court judge denied the motion, finding that Camuti had failed to meet his burden under G. L. c. 278A, § 7 (b), to demonstrate that a reasonably effective defense attorney would have sought to test Rakes' shirt for DNA.On appeal, the Supreme Judicial Court affirmed the lower court's decision. The court reasoned that the absence of trace evidence, including DNA evidence, was a central part of Camuti's defense strategy at trial. His counsel had repeatedly emphasized the lack of physical evidence linking Camuti to the crime scene, and the introduction of DNA evidence from Rakes' shirt could have undermined this defense. The court further noted that even if DNA testing had revealed the presence of a third party's DNA on the shirt, this would have had minimal exculpatory value given the circumstances of the case. Given these considerations, the court concluded that a reasonably effective attorney would not have sought DNA testing of Rakes' shirt. Therefore, Camuti had not met his burden under G. L. c. 278A, § 7 (b), and the denial of his postconviction motion for forensic testing was affirmed. View "Commonwealth v. Camuti" on Justia Law

The case involves the Commonwealth's appeal against the trial judge's denial of its motion to admit expert testimony on Frequent Location History (FLH) data retrieved from the defendant's cell phone in a murder case. The Commonwealth argued that the FLH data would corroborate its witness's testimony, placing the defendant at the crime scene. The trial judge denied the motion, stating that the Commonwealth had not met its burden of showing that FLH data had been generally accepted as reliable by the scientific community. The judge also found that the Commonwealth had failed to provide evidence that FLH data has been subjected to peer review or publication, has an unacceptably high known or potential rate of error, and is governed by recognized standards. The Supreme Judicial Court for the county of Suffolk agreed with the trial judge's decision, concluding that the Commonwealth had not shown that FLH data is reliable. Therefore, the court affirmed the trial judge's denial of the Commonwealth's motion to admit the FLH data. View "Commonwealth v. Arrington" on Justia Law

In 1995, the bodies of a woman and her daughter were found in separate locations in Massachusetts and Connecticut. More than two decades later, the woman's husband was convicted for her murder. On appeal, he asserted that the evidence was insufficient to establish his identity and deliberate premeditation, and challenged the admissibility of his daughter's murder evidence, the testimony of two latent print examiners, and the limitation on introducing a potential third-party culprit.The Supreme Judicial Court of Massachusetts affirmed the conviction. The court found no reversible error in the trial court's decisions and determined that the evidence was sufficient for the jury to find that the husband was the perpetrator and committed the crime with deliberate premeditation. The court also ruled that the evidence of the daughter's murder was admissible to establish the identity of the perpetrator of the mother's murder. The court also found no issues with the testimony of the latent print examiners and did not find any unfair limitations on the defendant's ability to present evidence of a potential third-party culprit. Furthermore, the court ruled that the defendant's rights to confront witnesses were not violated by the testimony of the latent print examiners. Lastly, the court deemed that the defendant's argument on the degree of certainty expressed by the latent print examiners was unpreserved, and the error did not create a substantial likelihood of a miscarriage of justice. View "Commonwealth v. Honsch" on Justia Law