Justia Criminal Law Opinion Summaries

The Supreme Judicial Court vacated Defendant's convictions for murder in the first degree on a theory of deliberate premeditation, argued assault with intent to murder, and assault and battery by means of a dangerous weapon, holding that the trial judge prejudicially erred when it denied defense counsel's request to conduct a voir dire examination of a key witness.On appeal, Defendant argued, among other things, that the judge erred in denying his request to conduct a voir dire examination of a key prosecution witness when defense counsel received an anonymous text message suggesting that a witness had falsely identified Defendant as part of a plot to frame him. The Supreme Court vacated Defendant's convictions, holding that the judge erred in denying defense counsel's request to conduct a voir dire examination of the key identification witness, and the error was prejudicial. View "Commonwealth v. Troche" on Justia Law

The Supreme Judicial Court affirmed the judgment of the single justice denying Petitioner's petition for relief citing Mass. Gen. Laws ch. 211, 3, Mass. Gen. Laws ch, 249, 5, Mass. Gen. Laws ch. 278, 28E, 28 U.S.C. 1292(b), and Mass. R. Crim. P. 15, holding that the single justice did not err or abuse his discretion in denying relief.Petitioner, who was awaiting trial on indictments for rape, strangulation or suffocation and other offenses, filed papers seeking review of the denial of certain pretrial motions and correction of other purported errors. The single justice denied all requests for relief. The Supreme Judicial Court denied Petitioner's appeal, holding that Petitioner failed to demonstrate that review of his claims could not adequately be obtained in the trial court or on appeal from his conviction. View "Ardaneh v. Commonwealth" on Justia Law

The Supreme Judicial Court vacated a portion of its prior order remanding this case to the superior court for entry of judgments of not guilty on indictments charging unlawful possession of a firearm, unlawful possession of ammunition, and unlawful possession of a loaded firearm, holding that this Court erred.Defendant was convicted of, inter alia, firearms-related convictions. The Supreme Judicial Court vacated Defendant's convictions and ordered that the superior court judge enter judgments of not guilty on the indictments, holding that, in light of the United States Supreme Court's decision in New York Stat Rifle & Pistol Ass'n v. Bruen, 142 S. Ct. 2111, 2122 (2022), which was entered after Defendant's convictions, the trial court judge erred when he failed to instruct the jury that Defendant lacked of a firearms license. The Court then granted the Commonwealth's motion for reconsideration, vacated the relevant portion of its prior order, and remanded the case for a retrial on those indictments, holding that because the constitutional rule established in Bruen did not exist at the time Defendant was convicted, the Commonwealth should have an opportunity to retry Defendant. View "Commonwealth v. Guardado" 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 Petitioner had no standing to obtain extraordinary relief in the instant matter.Petitioner filed an application in the district court for a criminal complaint charging an individual with witness intimidation and unlawful wiretapping. The application was denied due to lack of probable cause. Thereafter, Petitioner filed another application for criminal complaint in the Boston Municipal Court (BMC) charging the same individual with witness intimidation. The BMC found no probable cause and did not issue the complaint. Petitioner then brought this action, and the single justice denied relief without addressing the merits. The Supreme Judicial Court affirmed, holding that the single justice neither erred nor abused his discretion in denying relief. View "In re Two Applications for a Criminal Complaint" 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 under the statute.Petitioner was charged with one count each of assault and battery and witness intimidation. After an evaluation, a doctor recommended that Petitioner be found incompetent to stand trial and that he remain in the Tewksbury State Hospital, where he had been involuntarily committed for evaluation. Petitioner's counsel stipulated to incompetency but objected to further commitment. Petitioner was ultimately involuntarily committed for an additional thirty days. Petitioner then brought this petition asking the single justice to vacate the involuntary commitment order. The single justice denied the petition without holding a hearing. The Supreme Court affirmed, holding that Petitioner had an adequate alternative remedy. View "In re Impounded Case" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions for murder in the first degree based on a theory of felony-murder, among other charges, holding that a police officer's identification testimony was admitted improperly, but its admission did not prejudice Defendant.On appeal, Defendant challenged the denial of his motion to suppress, among numerous other allegations of error. For the claimed errors, Defendant requested that the court reduce his verdict or order a retrial. The Supreme Judicial Court affirmed, holding (1) a police officer's testimony identifying Defendant in a video recording at trial was improperly admitted, but the admission did not prejudice Defendant; and (2) Defendant was not entitled to relief on his remaining allegations of error. View "Commonwealth v. Fisher" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions of murder in the second degree and assault and battery by discharge of a firearm but vacated his convictions for carrying a firearm without a license and carrying a loaded firearm without a license, holding that the trial judge's failure to instruct the jury that the Commonwealth was required to prove an absence of a valid license created a substantial risk of a miscarriage of justice.At trial, Defendant sought to introduce Adjutant evidence or evidence of specific incidents of violence allegedly initiated by the victim. The trial judge allowed Defendant to introduce limited evidence of violent incidents initiated by the victim. The Supreme Judicial Court vacated Defendant's convictions in part, holding (1) the judge's ruling excluding additional testimony about the violent instances initiated by the victim exceeded the cope and purpose of Adjutant evidence, but there was no prejudice from its exclusion; (2) the trial judge did not err in the instruction regarding the jury's consideration of Adjutant evidence; and (3) pursuant to this Court's decision in Commonwealth v. Guardado, 491 Mass. 666 (2023), Defendant's firearm convictions must be vacated because the judge's failure to properly instruct the jury that Defendant did not have a license to carry a firearm was not harmless. View "Commonwealth v. Souza" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of two counts of murder in the first degree on theories of deliberate premeditation, extreme atrocity or cruelty, and felony-murder on a theory of joint venture and other crimes, holding that Defendant was not entitled to relief on her allegations of error.Specifically, the Supreme Judicial Court held (1) the trial judge did not err in denying Defendant's motion for change of venue, and Defendant failed to show any actual juror prejudice from the denial or that she was tried by anything but a fair and impartial jury; (2) the evidence was sufficient to prove Defendant's guilt as a joint venturer of murder in the first degree of the first victim; (3) there was also sufficient evidence to support Defendant's conviction of the first victim on the basis of felony murder; and (4) there was ample evidence to prove Defendant's guilt as a joint venturer of murder in the first degree on the basis of deliberate premeditation of the second victim. View "Commonwealth v. Smith" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of assault and battery by means of a dangerous weapon, holding that portions of the victim's then-girlfriend's grand jury testimony were properly admitted in accordance with the hearsay exemption for prior inconsistent statements.Prior to trial, the victim's then-girlfriend Shyla Bizarro identified Defendant as the victim's attacker from surveillance video footage and testified to her identification before the grand jury. Prior to her testimony, however, Bizarro revealed that she wished to recant her statements to police and her grand jury testimony. The trial judge admitted substantively the recanted portions of Bizarro's grand jury testimony, including her prior statements of identification. The Supreme Judicial Court affirmed the conviction, holding (1) the portions of Bizarro's grand jury testimony were properly admitted as prior inconsistent statements; (2) portions of Bizarro's grand jury testimony identifying Defendant in the video independently satisfied the hearsay exemption for statements of identification; and (3) there was no merit to Defendant's remaining arguments. View "Commonwealth v. Brum" on Justia Law

The Supreme Judicial Court vacated Defendant's firearm-related convictions but affirmed his convictions for murder in the first degree based on a theory of felony-murder, home invasion and armed assault with intent to rob, holding that the firearm-related convictions must be vacated in light of Commonwealth v. Guardado, 491 Mass. 666 (2023).Specifically, the Supreme Judicial Court held (1) trial counsel was not ineffective for failing to introduce certain categories of telephone calls; (2) there was no error in the denial of Defendant's motion for a new trial; (3) Defendant's convictions of unlawful possession of a firearm and unlawful possession of a loaded firearm must be vacated in light of this Court's precedent decision in Guardado; and (4) there was no reason for this Court to exercise its extraordinary authority pursuant to Mass. Gen. Laws ch. 278, 33E to grant Defendant a new trial or reduce the murder conviction to a lesser degree of guilt. View "Commonwealth v. Gibson" on Justia Law