Justia Civil Rights Opinion Summaries

After a jury trial, Defendant was convicted of assault by means of a dangerous weapon and several firearms charges. At trial, the Commonwealth proceeded under the theory that Defendant, who did not possess the gun used in the offense, was guilty of the charged offenses as a joint venturer. The court of appeals affirmed. Defendant appealed, contending, among other things, that his firearms convictions should be reversed because the Commonwealth failed to prove beyond a reasonable doubt that his coventurer had not been issued a license to carry a loaded firearm. The Supreme Court affirmed, holding (1) where a defendant is charged with a possessory firearms offense on a theory of joint venture, the defendant must raise the defense of license before trial, and Defendant in this case failed to do so; and (2) the remainder of Defendant's claims failed. View "Commonwealth v. Humphries" on Justia Law

After a jury trial, Defendant was convicted of assault and battery by means of a dangerous weapon. Defendant appealed, contending that the trial judge erred in giving a consciousness of guilt instruction pertaining to flight where Defendant proceeded on a theory of self-defense and claimed his flight was the result of fear brought on by the circumstances. The Supreme Court affirmed, holding that the judge properly acted within her discretion in giving an instruction on consciousness of guilt over Defendant's objection, where the judge instructed the jury that Defendant could not be convicted based on consciousness of guilt alone and did not use words tending to endorse as true any inference. View "Commonwealth v. Morris" on Justia Law

After a jury trial, Defendant was convicted of rape of a child with force and indecent assault and battery of a child under fourteen. Defendant appealed, arguing, among other things, that the superior court judge erred in denying his motion to suppress evidence obtained from a warrantless search of his apartment. The Supreme Court affirmed, holding (1) under the circumstances, the police possessed sufficient factual information when they determined that a person who appeared to have authority had given consent to enter Defendant's apartment, and therefore, Defendant's Fourth Amendment rights were not violated by the warrantless entry into the home; and (2) there was no merit to Defendant's other claims of error. View "Commonwealth v. Santos" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on a theory of deliberate premeditation. The Supreme Court affirmed, holding (1) the trial court did not err in suppressing Defendant's statements he made to police after he was arrested but before he received the Miranda warnings, as Defendant's statements were voluntary and not made as a result of any police prompting or coercion; (2) the remarks made by the prosecutor during his closing argument were either not improper or no substantial likelihood of a miscarriage of justice occurred due to the remarks; and (3) the trial court's jury instructions on voluntary manslaughter and use of excessive force in self-defense were in error, but under the circumstances, there was no substantial likelihood of a miscarriage of justice arising from the errors. View "Commonwealth v. Gonzalez" on Justia Law

Defendant was convicted of various sexual offenses and sentenced to a term of imprisonment. Prior to Defendant's scheduled release, the Commonwealth sought to commit Defendant as a sexually dangerous person. Defendant was temporarily committed and stipulated to probable cause. The Commonwealth subsequently filed a timely petition for trial. Defendant moved to dismiss the petition on the basis that the trial had not commenced within sixty days. The trial court denied the motion. The Supreme Court affirmed, holding that Defendant was not entitled as a matter of right to interlocutory relief because he had an adequate alternative remedy by way of an appeal. View "Flood v. Commonwealth" on Justia Law

Defendant filed this action against the Massachusetts Trial Court, alleging that it violated Mass. Gen. Laws ch. 151B by not selecting Defendant for two different promotions based on her age. A jury found in Defendant's favor with respect to one of the two positions. The trial judge then denied Defendant's motion for judgment notwithstanding the verdict but granted its motion for a new trial. Both parties appealed. The appeals court reversed the denial of the motion for judgment notwithstanding the verdict and vacated the order allowing the motion for a new trial. The Supreme Court remanded the case to the superior court, holding that because the judge granted the motion for a new trial, the appeal was premature, and the case should not have proceeded to an appellate court. View "Zaniboni v. Mass. Trial Court" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on the theory of felony-murder and unlawful possession of a firearm. Defendant and Joseph Morgan were tried separately for the crimes. The Supreme Court affirmed Defendant's convictions, holding that the trial judge (1) properly admitted the victim's statements to the 911 operator because the statements were excited utterances and were nontestimonial insofar as they were solicited for the primary purpose of enabling the police to assist in an ongoing emergency; (2) properly admitted the victim's statements to a responding police officer as dying declarations, concluding that the statements were not subject to the constraints of the confrontation clause; (3) did not err in declining to apply the doctrine of judicial estoppel to preclude the Commonwealth from arguing that the victim's intoxication did not affect his ability to identify Defendant as one of the shooters where the Commonwealth had previously argued at Morgan's trial that the victim's identification of Morgan had been unreliable because the positions taken by the Commonwealth at the two trials with respect to the reliability of the victim's identifications were distinct and not mutually exclusive. View "Commonwealth v. Middlemiss" on Justia Law

Defendant was incited for murder in the first degree and various counts of masked armed robbery. Pursuant to Mass. R. Crim. P. 14(b)(2), Defendant notified the Commonwealth that he intended to offer expert testimony concerning his mental state at the time of the alleged crime. The Commonwealth subsequently moved for a court-ordered psychiatric examination of Defendant, requesting disclosure of the custodians of Defendant's medical and psychiatric records and production and seeking the production of all such treatment records to the court. The motion judge denied the portion of the motion requesting disclosure of the custodians and production of Defendant's medical and psychiatric records. The Supreme Court reversed the motion judge's order insofar as it denied the Commonwealth's motion for access to Defendant's medical and psychiatric records on behalf of the Rule 14(b)(2)(B) examiner, holding that the examiner's review of the treatment records was necessary to conduct a meaningful examination and to produce the requisite reports. View "Commonwealth v. Hanright" on Justia Law

Defendants were two passengers and a driver in a vehicle pulled over by a police officer for a traffic offense. The defendant passengers left the scene despite the officer's order for them to return to the automobile. The defendant driver was arrested for driving without a valid license. Subsequently two police officers searched the vehicle and found a firearm and drugs. Defendants were charged with various drug and firearm offenses. Defendants moved to suppress the evidence seized from the vehicle. The superior court allowed the motions, concluding that the warrantless search of the vehicle was not justified under any exception to the warrant requirement. The Supreme Court affirmed, holding (1) because the firearm was not in plain view, the search could not be justified as a search incident to arrest; and (2) because the defendant passengers did not abandon the contents of the vehicle when they left the scene, the search of the vehicle constituted an unlawful warrantless search. View "Commonwealth v. Perkins" on Justia Law

Defendant was a sex offender subject to the requirements of the Sex offender Registration and Community Notification Act. Following his release in prison, Defendant pleaded guilty to failing to register as a sex offender in violation of Mass. Gen. Laws ch. 6, 178H(a). The district judge imposed a fine and imposed community parole supervision for life (CPSL). Defendant moved to vacate the imposition of CPSL and to withdraw his pleas. The judge denied Defendant's motions. The Supreme Court affirmed, holding (1) chapter 6, section 178H(a) authorizes the imposition of CPSL where the sentence is a fine; (2) the amendment of the complaint to add Defendant's prior convictions serving as predicate offenses for the imposition of CPSL was proper; (3) Defendant received effective assistance of counsel in connection with the plea process; (4) the district court judge correctly found Defendant was criminally liable for failing to register; and (5) the district court judge did not abuse her discretion in denying Defendant's motion for a new trial on the basis of newly discovered evidence. View "Commonwealth v. Domino" on Justia Law