Justia Civil Rights Opinion Summaries

Petitioner was convicted of multiple criminal offenses in 2005. In 2010, Defendant filed a motion for a new trial and an amended motion for a new trial. Neither motion was acted on. Defendant also represented that he filed two additional motions requesting action on his new trial motions but that those motions likewise were unresolved. Defendant filed a petition for relief under Mass. Gen. Laws ch. 211, 3, requesting that a single justice of the Supreme Court grant him a new trial for the reasons stated in the motions he filed in the trial court. The single justice denied the petition. The Supreme Court affirmed, as Petitioner did not (1) demonstrate he had availed himself of all measures available to him in the trial court to obtain a ruling on his motion, (2) provide copies of the motions he stated he filed in the trial court seeking action on his new trial motions, or (3) provide the single justice with a record adequate to support the specific relief he sought. View "Sellers v. Commonwealth" on Justia Law

In the underlying case, a superior court jury convicted Keith Winfield of forcible rape of a child under the age of sixteen, indecent assault and battery of a child under the age of fourteen, and assault and battery of a child causing serious bodily injury. The appeals court affirmed. Steve Audette, a film producer, was making a documentary film about Winfield's prosecution and convictions. After Audette purchased an official transcript of the trial, Audette filed a motion to access an audiotape room recording of the trial made by a court reporter. The motion judge denied the motion. The Supreme Court affirmed, holding (1) where the court reporter's room recording is not the official record of the trial and is not filed with the court or referenced in the court file, Audette was not entitled to a copy under the public's right of access to criminal proceedings guaranteed by the First Amendment or under the State's common-law right of access to judicial records; and (2) the judge did not abuse her discretion in refusing to give Audette access to the recording. View "Commonwealth v. Winfield" on Justia Law

After a jury trial, Defendant was convicted of one count of murder in the first degree and two counts of armed robbery. Defendant did not appeal. Nearly forty-five years later, Defendant filed a motion for a new trial, collaterally attacking his conviction. A judge denied Defendant's amended motion and granted Defendant leave to renew that motion subject to the outcome of his co-defendant's appeal from the denial of a similar motion for new trial. Rather than awaiting the outcome of that case, Defendant appealed the denial of his motion. The Supreme Court subsequently affirmed the denial of the co-defendant's motion for a new trial and concluded that the Court's decision in that case was controlling in the present appeal. The Court affirmed the judge's denial of Defendant's motion for a new trial, holding that the judge's denial of Defendant's motion for new trial was not manifestly unjust, nor was the trial infected with prejudicial constitutional error. View "Commonwealth v. Robideau" on Justia Law

After a jury trial, Defendant and his co-defendant were convicted of felony-murder in the first degree and armed robbery. The Supreme Court (1) affirmed Defendant's conviction of felony-murder in the first degree, holding, among other things, that (i) the evidence was sufficient to support the conviction, (ii) the trial judge erred in admitting evidence of a prior bad act of the co-defendant, but the error was harmless, (iii) the judge did not err in its instructions to the jury, and (iv) Defendant was not entitled to a new trial where the Court concluded that the co-defendant was entitled to a new trial due to errors at trial; and (2) vacated the armed robbery conviction, as it was duplicative of the murder conviction. View "Commonwealth v. Benitez" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree. The Supreme Court affirmed the conviction and the denial of Defendant's motion for a new trial. Defendant later filed a second motion for a new trial, alleging that his counsel was ineffective for failing to raise certain alleged errors at trial and on direct appeal. The superior court denied the motion. The Supreme Court affirmed the order denying the motion for a new trial, holding (1) trial counsel was not constitutionally ineffective in failing to object to two courtroom closures; (2) the trial judge improperly limited the scope of Defendant's cross-examination of a witness for the prosecution, but the error was harmless; (3) Defendant's appellate counsel was not ineffective for failing to cite federal law to support Defendant's claims of error on direct appeal; (4) the trial judge did not err in declining to give a Bowden instruction; and (5) the trial judge properly instructed the jury on consciousness of guilt. View "Commonwealth v. Hardy" on Justia Law

After a jury trial, Defendant was convicted of carrying a firearm without a license based on a theory of constructive possession. Defendant appealed, contending, among other things, that the Commonwealth failed to present sufficient evidence to establish as a matter of law that Defendant had knowledge of the firearm's presence in his vehicle, the ability to exercise control over the weapon, and the intent to do so. The Supreme Court reversed Defendant's conviction and directed that a verdict of not guilty be entered, holding that although the evidence proffered by the Commonwealth was adequate to establish that Defendant knew the firearm was present in the motor vehicle he was operating and that he had the ability to exercise control over the weapon, the evidence was insufficient to prove Defendant had the requisite intention to control the firearm. View "Commonwealth v. Romero" on Justia Law

Defendant was indicted on drug-related charges that included trafficking in cocaine over twenty-eight grams. During the trial, certificates of chemical analysis establishing the weight and identity of the substance alleged to have been in Defendant's possession (drug certificates) were admitted into evidence. Defendant was convicted of the charges. After Defendant appealed, the U.S. Supreme Court issued its decision in Melendez-Diaz v. Massachusetts, which held that a drug analyst's certificate is testimonial and cannot be admitted at trial unless a defendant has the opportunity to cross-examine the analyst. Defendant then filed a motion for a new trial, arguing that the admission of the drug certificates violated his right to confrontation. The judge denied the motion, concluding that admission of the drug certificates was harmless beyond a reasonable doubt. The Supreme Court vacated Defendant's convictions and remanded the case for a new trial, holding that the erroneous admission of the drug certificates was not harmless beyond a reasonable doubt. View "Commonwealth v. Montoya" on Justia Law

Defendant was convicted of the deliberately premeditated murder of his wife. The Massachusetts Supreme Court affirmed, but the U.S. Supreme Court vacated the judgment and remanded the case in light of the recent U.S. Supreme Court decision in Williams v. Illinois, which addressed the admissibility under the Confrontation Clause of expert testimony about the results of DNA testing performed by non-testifying analysts. On remand, the Court reconsidered of the admissibility of testimony of an expert witness regarding DNA testing where the witness did not prepare the underlying data. The Supreme Court affirmed, holding (1) the Court's rules of evidence and the protections they afford are not inconsistent with Williams; (2) the witness's expert opinion that Defendant's DNA matched the DNA on items recovered from the crime scene was properly admitted; and (3) the witness's direct testimony to the details of the DNA test results of a nontestifying analyst was improperly admitted, but Defendant was not prejudiced by the erroneous admission. View "Commonwealth v. Greineder" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on the theory of extreme atrocity or cruelty. Defendant appealed, arguing that the trial court erred in denying his motion to suppress statements he made to police and his motion for a new trial. The Supreme Court affirmed, holding (1) the motion judge did not err in denying Defendant's motion to suppress and concluding that the Commonwealth satisfied its burden of proving beyond a reasonable doubt that Defendant made a knowing, willing, and intelligent waiver of his Miranda rights and that his statements were otherwise voluntarily made; and (2) the motion judge did not err in denying Defendant's motion for a new trial on the ground that his trial counsel provided ineffective assistance by failing to file a pretrial motion to suppress a witness's identification of Defendant, as Defendant failed to demonstrate a likelihood that a motion to suppress this evidence would have been successful. View "Commonwealth v. Jules" on Justia Law

Defendant was convicted of murder in the first degree, armed assault with intent to murder, and two counts of illegal possession of a firearm. The Supreme Court affirmed the convictions, holding (1) the trial judge did not err in limiting cross-examination of the Commonwealth's principal witness; (2) the trial court did not err in admitting a police officer's testimony, which, contrary to Defendant's assertion, did not improperly vouch for the principal witness's testimony; (3) the trial judge did not err in declining to sequester the police witnesses who were involved in the investigation and who had conducted interviews of the principal witness; and (4) the prosecutor did not improperly vouch for Commonwealth witnesses or misstate evidence during his closing argument. View "Commonwealth v. Ahart" on Justia Law