Justia Civil Rights Opinion Summaries

In 2004, after a jury trial, Defendant was convicted of murder in the second degree. During jury empanelment, the court officers closed the court room to all members of the public, including Defendant’s family and friend. In 2008, after Defendant unsuccessfully filed a motion for a new trial and unsuccessfully appealed, Defendant filed a second motion for new trial, claiming that the closure of the court room was structural error requiring reversal. On remand, the motion judge denied the motion, concluding that the brief closure of the court room for jury empanelment was de minimis. The Supreme Court affirmed the denial of Defendant’s motion for new trial but on other grounds, holding (1) although the closure of the court room for the entire empanelment process was not de minimis, Defendant waived his right to a public trial where his experienced trial counsel was aware that the court room was routinely closed to spectators during the jury empanelment process and did not object; and (2) counsel’s failure to object did not deprive Defendant of the effective assistance of counsel. View "Commonwealth v. Alebord" on Justia Law

After a jury trial, Defendant was convicted of murder and related firearm charges. The appeals court affirmed. Defendant appealed, arguing that the trial court erred in denying his motion to suppress statements he made to the police during an interview at the police station. The Supreme Court affirmed, holding that the trial court did not err in admitting the statements where (1) because Defendant’s claimed invocations of the right to counsel were made before the interrogation became custodial, Defendant did not effectively invoke that right; (2) the totality of the circumstances supported the conclusion that Defendant’s statements were voluntary; and (3) even if Defendant did not validly waive his Miranda rights before making statements during the custodial portion of the interview, the admission of those statements was harmless beyond a reasonable doubt. View "Commonwealth v. Molina" on Justia Law

After a jury trial, Defendant, who was a juvenile at the time of the offense for which he was found guilty, was convicted of murder in the first degree for his knowing participation along with three other young men in the killing of the victim. The Supreme Court (1) affirmed Defendant’s conviction, holding (i) Defendant’s trial counsel did not render constitutionally deficient assistance by failing to obtain a full transcript of a witness’s testimony from another trial for impeachment purposes, (ii) the admission of state of mind evidence did not prejudice Defendant under the circumstances, and (iii) the prosecutor’s inconsistent closing argument at another trial related to the killing and Defendant’s trial did not prejudice Defendant; and (2) vacated Defendant’s sentence and remanded for resentencing, holding that Defendant’s sentence of life in prison without parole was invalid under the Eighth Amendment. View "Commonwealth v. Keo" on Justia Law

Defendant was convicted of two indictments alleging receipt of stolen property. Defendant appealed, arguing that the judge erred in denying his motion to suppress because the arrest warrants leading to the search of an apartment where the stolen property was discovered did not authorize the police to enter the apartment. Specifically, Defendant argued that the police did not have a “reasonable belief” that Defendant was present in the apartment, and therefore, the subsequent seizure of the stolen property was the fruit of this unconstitutional entry. The Supreme Court vacated the convictions and remanded, holding (1) a “reasonable belief” requires more than was known at the time of entry in this case; and (2) therefore, the entry was unconstitutional, and the observation and subsequent seizure of the stolen property allegedly received by Defendant should have been suppressed as the fruit of the illegal entry. View "Commonwealth v. Gentile" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on the theories of deliberate premeditation and extreme atrocity or cruelty. The Supreme Court affirmed Defendant’s convictions and the denial of his motion for a new trial, holding (1) Defendant’s Sixth Amendment right to a public trial was not violated when the trial judge ordered that, before entering the court room, each spectator must sign in and give a source of identification to the court officer posted outside the court room; (2) the trial judge did not err by admitting into evidence grand jury testimony of a prosecution witness; (3) the admission of certain hearsay did not create a substantial likelihood of a miscarriage of justice; and (4) the trial judge did not violate Defendant’s right to be tried by an impartial jury by failing to conduct a voir dire of all the jurors after one juror expressed concern that Defendant had access to the juror’s address in the juror’s confidential questionnaire. View "Commonwealth v. Maldonado" on Justia Law

Following a jury trial nearly three years after his initial arraignment, Defendant was convicted of disorderly conduct and assault by means of a dangerous weapon. The Supreme Court reversed Defendant’s convictions and dismissed the complaints against him, holding (1) Defendant was denied a speedy trial, and any failures by his trial counsel to perfect that claim constituted ineffective assistance of counsel; and (2) the trial judge’s order of restitution to compensate a police officer whose glasses were damaged during his interaction with Defendant was constitutional under Apprendi v. New Jersey and met the “causal connection” requirement for such awards under Commonwealth v. McIntyre. View "Commonwealth v. Denehy" on Justia Law

Defendant was convicted of first degree murder on a theory of joint venture and sentenced to life in prison. Defendant appealed, arguing, among other things, that the trial judge erred in finding that he was not a target of the investigation, and because he was a target, the Commonwealth was required to advise him of his Fifth Amendment right to avoid self-incrimination. The Supreme Court affirmed, holding (1) the evidence was sufficient to permit a jury to find Defendant guilty of murder in the first degree; (2) the trial judge did not err in determining that Defendant was not a target of the investigation at the time of his grand jury testimony, but a new prospective rule requires the Commonwealth to advise targets or potential targets of the grand jury’s investigation of their right not to incriminate themselves; and (3) Defendant was not entitled to a DiGiambattista instruction where it was not requested at trial. View "Commonwealth v. Woods" on Justia Law

Defendant was convicted of murder in the first degree and sentenced to a mandatory term of life imprisonment without the possibility of parole. Defendant was seventeen years old at the time of the offense. The U.S. Supreme Court subsequently decided Miller v. Alabama, which held that the imposition of a mandatory sentence of life imprisonment without parole on persons under the age of eighteen at the time they committed the murder violates the Eighth Amendment. Consequently, Defendant filed a petition challenging the constitutionality of the sentencing scheme for murder in the first degree as applied and sought a declaration that article 26 of the Massachusetts Declaration of Rights bars the imposition of a sentence of life imprisonment for juvenile homicide offenders. The Supreme Court held (1) Miller has retroactive application to cases on collateral review; and (2) the mandatory imposition of a sentence of life in prison without the possibility of parole on individuals who were under age eighteen when they committed first degree murder violates the prohibition on cruel or unusual punishments in article 26, and the discretionary imposition of such a sentence on juvenile homicide offenders also violates article 26 because it is an unconstitutionally disproportionate punishment. View "Diatchenko v. Dist. Attorney" on Justia Law

Defendant committed murder when he was seventeen years old. Defendant was subsequently convicted in the superior court of murder in the first degree and related weapons charges. While Brown was awaiting trial, the U.S. Supreme Court decided Miller v. Alabama, which held that mandatory life-without-parole sentences for juvenile homicide offenders violate the Eighth Amendment. The statutory sentencing scheme in Massachusetts requires, however, that all defendants over the age of fourteen who are convicted of murder in the first degree must be sentenced to life without the possibility of parole. Consequently, Defendant's sentencing was stayed until the Maine Supreme Court could render an opinion regarding the issue. The Supreme Court concluded that Defendant was entitled to the benefit of Miller and Commonwealth v. Diatchenko, in which the Court held that all life-without-parole sentences for juvenile offenders violate the Massachusetts Declaration of Rights. Consequently, the Court held that Defendant may not be sentenced to life without parole. Remanded for sentencing. View "Commonwealth v. Brown" on Justia Law

Petitioner was indicted on charges of murder, unlawful possession of a firearm, and attempted armed robbery, among other charges. The Commonwealth filed a motion for a protective order to limit the discovery of witnesses' identifying information. A judge allowed the motion in part, ordering that witnesses' addresses and telephone numbers not be disclosed to Petitioner. Petitioner filed this petition for review pursuant to Mass. Gen. Laws ch. 211,3 arguing that the order deprived him of his constitutional rights, including his ability to prepare a defense. A single justice denied relief. The Supreme Court affirmed, holding that Petitioner's issues could be adequately and effectively explored on direct appeal, if and when Petitioner was convicted. View "Madison v. Commonwealth" on Justia Law