Justia Civil Rights Opinion Summaries

Defendant was convicted by a jury of murder in the first degree on a theory of deliberate premeditation in the stabbing death of her boyfriend. Defendant appealed from both her conviction and the denial of her motion for a new trial. The Supreme Court reversed Defendant's conviction and remanded the matter for a new trial because (1) on multiple occasions, over objection, the trial judge erroneously allowed the Commonwealth to introduce highly prejudicial evidence of Defendant's prior bad acts; and (2) the judge later declined to provide an instruction as to the excessive use of force in self-defense that was supported by the evidence. View "Commonwealth v. Anestal" on Justia Law

Defendant filed a petition seeking reversal of an order of the superior court that denied Defendant's motion to correct his jail time credit to include fourteen days spent in custody awaiting trial on charges pertaining to various property crimes. The motion was filed nearly five years after Defendant had completed his sentence on an unrelated rape conviction and sought to apply the fourteen days of credit to that sentence. The receipt of such credit would have had the effect of granting Defendant an earlier release date on the rape conviction. As a consequence, Defendant no longer would have been a lawful "prisoner" at the time the Commonwealth filed a petition for his civil commitment as a sexually dangerous person and, therefore, would not have been subject to such a commitment. The superior court concluded that Defendant's motion was untimely and moot. A single justice denied his petition for extraordinary relief. The Supreme Court affirmed, holding that Defendant's claim for jail time credit should have been raised while he still was serving his sentence on the rape conviction when, if appropriate, relief could have been afforded. View "Williams v. Superintendent, Mass. Treatment Ctr." on Justia Law

This appeal, filed by brothers Gary and Dennis Baasch (Appellants), concerned disputed land located in Howard County. After a bench trial, the district court for Howard County denied Gary Baasch's counterclaim for quiet title. The court found that husband and wife Paul and Betty Lou Obermiller (Appellees) owned all the land they claimed to own, that the fence constructed by Appellants was on Appellees' land, and that Gary Baasch did not own any of the disputed land. The court also found that Appellants had trespassed, ordered them to remove the fence, and enjoined them from blocking access to the land owned by Appellees. The Supreme Court vacated the board's decision, holding that the district court correctly concluded (1) Appellees were the rightful owners of the disputed land; (2) because Appellees owned the land, Appellants' intentional installation of a fence on the land constituted a continuous trespass; and (3) Appellees were entitled to an injunction. Remanded. View "Schoeller v. Bd. of Registration of Funeral Dirs. & Embalmers" on Justia Law

At issue in this case was whether the crime of leaving the scene of an accident where death resulted requires the Commonwealth to prove that the defendant knew he collided with a person. Because the superior court judge initially agreed with the Commonwealth that it had no such burden, he found Defendant guilty. However, the judge allowed Defendant's motion for relief from judgment on the ground that the Commonwealth did have such a burden of proof, and ordered a judgment of acquittal to be entered. The Commonwealth appealed. The Supreme Court affirmed, holding that under Mass. Gen. Laws ch. 90, 24(2)(a 1/2)(2), the Commonwealth must prove the defendant knew he collided with or otherwise caused injury to a person. View "Commonwealth v. Daley" on Justia Law

After a jury trial, Defendant was convicted of unlawful possession of a firearm and unlawful possession of a loaded firearm. In addition, Defendant was convicted after a jury-waived trial of violating the armed career criminal statute. The only ammunition in evidence was that which was loaded in the firearm. The appeals court (1) reversed the convictions on the ground that certificates of ballistics analysis were admitted in violation of Defendant's constitutional right to confront witnesses against him; and (2) directed the entry of judgment for Defendant on the loaded firearm charge on the ground that, where he had been acquitted of possessing the ammunition that was loaded into the firearm, retrial on that charge would violate double jeopardy protections and principles of issue preclusion. The Supreme Court reversed in part, holding that Defendant's acquittal on the ammunition charge did not preclude retrial on the loaded firearm charge. View "Commonwealth v. Charles" on Justia Law

After a mistrial at which the jury was deadlocked, Defendant was retried and convicted of two indictments charging murder in the first degree on a theory of deliberate premeditation. The Supreme Court affirmed the convictions, holding (1) the trial court properly disallowed Defendant's claims that his motion to dismiss the indictments, filed before retrial, because the Commonwealth presented legally sufficient evidence at his first trial; (2) a second trial in these circumstances did not violate constitutional and common-law prohibitions against double jeopardy; (3) the trial judge did not err in his evidentiary rulings or in failing to instruct the jury pursuant to Commonwealth v. Bowden. View "Commonwealth v. Fitzpatrick" on Justia Law

Defendant was convicted by a jury of murder in the first degree, armed assault with intent to kill, assault with a dangerous weapon, and various firearms offenses. The Supreme Court affirmed Defendant's convictions and declined to grant him a new trial or to reduce the verdict to a lesser degree of guilt, holding (1) the trial judge did not abuse his discretion in allowing the peremptory challenge of an African-American juror; (2) the trial judge erred in admitting certain evidence concerning Defendant's juvenile record, but the error was harmless; (3) although some of the prosecutor's statements during closing argument may have exceeded the bounds of permissible argument, they were unlikely to have affected the jury's verdicts; (4) the trial judge did not err in concluding that Defendant was not entitled to an instruction on the use of force in defense of another; and (5) the trial court did not err in denying Defendant's motion for a new trial based on Defendant's assertion that he received ineffective assistance of trial counsel. View "Commonwealth v. Scott" on Justia Law

A jury convicted of Defendant of being an accessory before the fact to murder. The Supreme Court reversed Defendant's conviction because the evidence did not establish that he had done any act before the assault to counsel, hire, or otherwise procure the assault. The Commonwealth subsequently sought and the grand jury returned an indictment charging Defendant with murder for his involvement in the killing. Defendant moved to dismiss the indictment, arguing that, because murder was a form, or a "species," of the lesser included offense of accessory before the fact to murder, a second prosecution was barred by double jeopardy. A judge denied the motion. The Supreme Court affirmed, holding (1) the indictment that charged Defendant with murder in the first degree did not violate the prohibition against double jeopardy; and (2) under the circumstances of this case, given the erroneous jury instructions and the erroneous admitted evidence, prosecution of Defendant for murder in the first degree was not barred on grounds of double jeopardy. View "Marshall v. Commonwealth" on Justia Law

After a jury conviction, Defendant was convicted of deliberately premeditated murder. The Supreme Court affirmed the conviction and declined to reduce the verdict or order a new trial, holding that the trial court did not err in (1) refusing to instruct the jury that they could consider evidence of voluntary intoxication on the question of Defendant's capacity to premeditate deliberately; (2) refusing to instruct the jury that they could return a verdict of voluntary manslaughter based on evidence of reasonable provocation or mutual combat; and (3) denying Defendant's motion for a new trial based on his claim of a closure of the court room during jury selection, as Defendant failed to meet his burden of showing there was a general or even a partial closure of the court room. View "Commonwealth v. Lennon" on Justia Law

A jury convicted Defendant of murder in the first degree on the theories of deliberate premeditation and extreme atrocity or cruelty, and of possession of a firearm without a license. The Supreme Court affirmed the order denying Defendant's motions to suppress and affirmed the judgments of conviction, holding (1) the pretrial judge did not abuse his discretion in denying Defendant's request for a continuance so that he could change counsel; (2) the trial court did not abuse his discretion in declining to allow Defendant to discharge his appointed counsel; (3) the trial court did not err in denying Defendant's motions to suppress statements; (3) the trial judge did not err in his instructions to the jury; and (4) there was no basis on which to grant Defendant relief pursuant to Mass. Gen. Laws 278, 33E by reducing the murder verdict to a lesser degree of guilt or granting Defendant a new trial. View "Commonwealth v. Delacruz" on Justia Law