Justia Civil Rights Opinion Summaries

The case involves Roberto Cruz, who was convicted of two counts of indecent assault and battery on a child under the age of fourteen. The incidents occurred when Cruz, nearly sixty years old, hugged and kissed a thirteen-year-old girl, Jane, without her consent. Cruz was also charged with child enticement and simple assault and battery, but the latter charge was dismissed by the Commonwealth before the trial. The jury acquitted Cruz of child enticement and one count of indecent assault and battery but convicted him of the other two counts.Cruz appealed his convictions, arguing that the evidence was insufficient to prove the assaults were indecent. The Massachusetts Appeals Court agreed, reversing his convictions on the grounds that the conduct did not meet the statutory definition of indecent assault and battery. Following this reversal, Cruz filed a civil lawsuit seeking compensation for wrongful conviction under G. L. c. 258D. The Commonwealth moved for summary judgment, arguing that the reversal did not establish Cruz's innocence of the simple assault and battery charge, which had been dismissed earlier.The Supreme Judicial Court of Massachusetts reviewed the case. The court held that the eligibility for compensation under G. L. c. 258D is limited to felony convictions and does not include misdemeanors like simple assault and battery. Therefore, the court affirmed the Superior Court's denial of the Commonwealth's motion for summary judgment and remanded the case for further proceedings. The court concluded that Cruz met the eligibility requirements for compensation as the reversal of his felony convictions tended to establish his innocence of those charges. View "Cruz v. Commonwealth" on Justia Law

The case involves a probationer who was arrested during a traffic stop and subsequently charged with possession of cocaine with intent to distribute and unlawful possession of a firearm. During the traffic stop, a state trooper observed the vehicle speeding and making unsafe lane changes. Upon stopping the vehicle, the trooper noticed suspicious behavior from the back seat passenger and found drugs and a firearm in the vehicle. The probationer was found to have thrown a bag containing drugs to the back seat passenger as the vehicle was being pulled over.The Superior Court judge found the probationer in violation of his probation conditions, revoked his probation, and sentenced him to state prison. The probationer appealed, arguing that the evidence was insufficient to prove he possessed cocaine with intent to distribute and unlawfully possessed a firearm. He also claimed ineffective assistance of counsel for not moving to suppress the evidence on equal protection grounds, alleging racial animosity by the state trooper.The Supreme Judicial Court of Massachusetts reviewed the case and upheld the lower court's decision. The court found sufficient evidence to support the probation violation, including the possession and intent to distribute cocaine and the unlawful possession of a firearm. The court also rejected the claim of ineffective assistance of counsel, stating that the exclusionary rule does not generally apply to probation revocation proceedings and that the counsel's performance did not fall below the standard of an ordinary fallible lawyer.The court affirmed the revocation of probation and the denial of the motion for a new hearing. View "Commonwealth v. Gelin" on Justia Law

The defendant was convicted of sexual offenses against his granddaughter and sentenced to state prison followed by five years of supervised probation. The probation conditions included GPS monitoring and a requirement to stay away from the victim and her family. After his release, the defendant moved to vacate the GPS condition, arguing it was unconstitutional without an individualized determination of its reasonableness, as required by a recent court decision.The Superior Court judge denied the motion, finding the GPS condition reasonable and added exclusion zones for the cities of Framingham and Marlborough, which were not specified in the original sentence. The defendant appealed, arguing that the GPS condition was unreasonable and that adding exclusion zones violated double jeopardy principles.The Supreme Judicial Court of Massachusetts reviewed the case. It held that the addition of exclusion zones did not violate double jeopardy because the original sentence contemplated such zones. However, the court found that the scope of the exclusion zones, covering entire cities, was overly broad and increased the severity of the defendant's sentence. The court affirmed the GPS condition as reasonable, given the seriousness of the offense and the defendant's moderate risk of reoffense, but remanded for revision of the exclusion zones to be consistent with statutory and probationary goals.The court also directed the probation department to remove GPS monitors from defendants who had not received a reasonableness hearing and to refrain from attaching monitors until such hearings are held, ensuring compliance with constitutional requirements. View "Commonwealth v. Rodriguez" on Justia Law

F.A. has been involuntarily committed to state mental health facilities since 1999 after being found not guilty of a sexual offense due to mental illness. In 2020, a District Court judge renewed F.A.'s commitment and imposed a restriction confining F.A. to the buildings and grounds of the facility. F.A. challenged the constitutionality of this restriction.Previously, the Worcester Division of the District Court Department had renewed F.A.'s commitment annually and imposed similar restrictions since 2013. In 2020, F.A. opposed the Commonwealth's motion for the restriction, but the judge granted it after an evidentiary hearing. The judge did not require the Commonwealth to prove beyond a reasonable doubt that the restriction was necessary. In 2021, a different judge imposed the same restriction without an evidentiary hearing. The Appellate Division of the District Court affirmed the 2020 restriction but vacated the 2021 restriction due to the lack of a hearing. F.A. appealed the 2020 decision, and the Supreme Judicial Court granted direct appellate review.The Supreme Judicial Court of Massachusetts reviewed the case and found that the 2020 order violated F.A.'s substantive and procedural due process rights. The court held that a restriction under G. L. c. 123, § 16 (e) must be narrowly tailored to a compelling government interest and be the least restrictive means available. The judge failed to make such findings and did not consider less restrictive alternatives. Additionally, the court found that the judge used an incorrect standard of proof and did not provide timely, specific findings to support the restriction. Consequently, the court vacated the 2020 order. View "In the Matter of F.A." on Justia Law

The plaintiffs, all State troopers, filed a lawsuit against the Commonwealth and the heads of the State Police and the State Board of Retirement. They claimed that the defendants' policy of denying the accrual of benefits, such as seniority, length-of-service credit, and vacation and sick time while on leave under the Paid Family and Medical Leave Act (PFMLA), violated the act. Additionally, they argued that the policy discriminated against female employees in violation of other state laws.A Superior Court judge dismissed the portion of the complaint alleging violations of the PFMLA. The judge concluded that the act does not guarantee the accrual of benefits during PFMLA leave. The plaintiffs then sought clarification on the interpretation of the act, and the case was reported to the Appeals Court. The Supreme Judicial Court of Massachusetts transferred the case to itself for review.The Supreme Judicial Court of Massachusetts held that the PFMLA does not require employers to guarantee the accrual of vacation and sick time during an employee's leave. The court interpreted the plain language of the statute, particularly sections 2(e) and 2(f), and concluded that while employees must be restored to their previous position with the same status and benefits upon returning from leave, the act does not mandate the continued accrual of benefits during the leave period. The court affirmed the lower court's dismissal of the PFMLA claims and remanded the case for further proceedings consistent with its opinion. View "Bodge v. Commonwealth" on Justia Law

The case involves the defendant, who was indicted for unlawful possession of a firearm and related offenses after Boston police officers monitored his Snapchat account and observed him brandishing firearms in several videos. The police used an undercover Snapchat account to send a friend request to the defendant, who accepted it, allowing the officers to view his posts. The defendant was arrested twice, once in January 2018 and again in May 2018, each time after posting videos showing him with firearms.In the Superior Court, the defendant filed multiple discovery motions seeking information about the Boston Police Department's (BPD) use of undercover social media monitoring, arguing that it was relevant to an equal protection claim of discriminatory enforcement. The court granted these motions, ordering the Commonwealth to disclose various pieces of information, including the usernames and profile images used by undercover officers. The Commonwealth refused to comply, citing concerns about compromising ongoing investigations and endangering informants.The Supreme Judicial Court of Massachusetts reviewed the case. The court held that the Commonwealth did not properly assert a privilege to withhold the requested information, as it failed to demonstrate a legitimate need to protect ongoing investigations or the safety of informants. The court also affirmed the lower court's application of the equal protection standard from Commonwealth v. Long, which applies to claims of discriminatory law enforcement practices beyond traffic stops.The court concluded that the Superior Court judge did not abuse his discretion in dismissing the indictments with prejudice as a sanction for the Commonwealth's deliberate non-compliance with the discovery order. The dismissal was deemed appropriate because the Commonwealth's refusal to provide the requested discovery denied the defendant the opportunity to develop his equal protection claim, thus preventing a fair trial. View "Commonwealth v. Dilworth" on Justia Law

A juvenile was indicted as a youthful offender for unarmed carjacking, unarmed assault with intent to rob, and assault and battery on an elder. The charges stemmed from an incident where the juvenile, after escaping from a secure facility, attacked an elderly man and stole his car. The juvenile pleaded guilty and was sentenced to two years in a house of correction followed by five years of probation.The Juvenile Court initially sentenced the juvenile to a house of correction, but after multiple probation violations, including missing appointments and being involved in new offenses, the court sentenced him to State prison. The juvenile appealed the sentence, arguing it was unlawful and that the judge did not adequately consider his well-being and the impact of recent literature on juvenile brain development.The Supreme Judicial Court of Massachusetts reviewed the case. The court found that the juvenile's sentence was lawful under G. L. c. 119, § 58, which allows for adult sentences, including State prison, for youthful offenders. The court determined that the Juvenile Court judge had appropriately considered the juvenile's criminal history, noncompliance with probation, and the need for public safety. The court also concluded that the judge did not need to make specific written findings on the impact of juvenile brain development literature.Additionally, the Supreme Judicial Court held that the Appellate Division of the Superior Court is authorized to review sentences to State prison imposed by the Juvenile Court on youthful offenders. This ensures that youthful offenders have the same procedural safeguards as adult criminal defendants. The court affirmed the juvenile's sentence and allowed for the appeal to the Appellate Division. View "Commonwealth v. Y." on Justia Law

The case revolves around Quasim Hastings, a prisoner convicted of second-degree murder in 2004 and eligible for parole consideration. Hastings, diagnosed with a mental disability, is entitled to a parole hearing that provides him with protections under the Massachusetts Constitution and Federal and State statutes prohibiting discrimination based on disability. Prior to a 2023 parole hearing, Hastings' counsel filed a motion for funds to retain a forensic psychologist and a social services advocate to assist with preparing a prerelease plan. While the motion for a forensic psychologist was approved, the request for a social services advocate was denied by a different Superior Court judge, who reasoned that the indigency statute limits his authority to approve funds to pending proceedings or appeals in any court.The judge's denial of the motion for funds was reported to the Appeals Court, and Hastings's application for direct appellate review was granted by the Supreme Judicial Court. The Supreme Judicial Court concluded that Hastings's motion for funds to retain a social services advocate implicates his State constitutional right to reasonable disability accommodations. Therefore, the constitutionally mandated exception to the indigency statute applies, and the order denying Hastings's motion for funds was reversed. The court held that a judge has the discretion to allow a motion for funds to pay for expert assistance as reasonably necessary to safeguard the indigent prisoner's constitutional rights prohibiting discrimination on the basis of disability. View "Commonwealth v. Hastings" on Justia Law

The case involves a group of petitioners who challenged a trial court's decision to establish a 200-foot buffer zone around the Norfolk County Superior Court House during the trial of a high-profile murder case. The buffer zone was created in response to protests and demonstrations near the courthouse, which the Commonwealth argued could jeopardize a fair trial. The petitioners, who sought to intervene in the trial court proceedings to oppose the buffer zone, argued that it infringed on their First Amendment rights.The trial judge allowed the Commonwealth's motion for a buffer zone, albeit reducing it from the requested 500 feet to 200 feet. The judge denied the petitioners' motion to intervene, arguing that the buffer zone was necessary to ensure a fair trial and to protect jurors and witnesses from potential intimidation or harassment. The petitioners subsequently filed petitions for relief from both the buffer zone order and the denial of their motion to intervene.The single justice of the Supreme Judicial Court denied the petitions, concluding that the trial judge's decision was an ordinary procedural ruling and did not warrant the court's extraordinary power of general superintendence. The single justice also found that the buffer zone met the "reasonable restriction" requirements, being content-neutral, narrowly tailored to serve a significant governmental interest, and leaving open ample alternative channels for communication.The Supreme Judicial Court affirmed the single justice's decision, rejecting the petitioners' argument that the buffer zone order should be analyzed under strict scrutiny as a prior restraint on speech. The court found that the buffer zone did not forbid protestors from expressing their message, but merely restricted where they could do so. The court also noted that the petitioners failed to provide sufficient evidence to establish that the buffer zone extended onto public sidewalks or other areas constituting a public forum. View "Spicuzza v. Commonwealth" on Justia Law

In the case of Commonwealth v. Rashad Shepherd, the Supreme Judicial Court of Massachusetts affirmed the defendant’s conviction of murder in the first degree on the theory of felony-murder, with attempted unarmed robbery as the predicate felony. The case centered around a failed robbery attempt that ended in the shooting and death of the intended victim. The defendant, along with two co-conspirators, hatched a plan to rob the victim, who was known to sell marijuana from his apartment. However, when the plan was put into motion, the victim resisted, and in the ensuing altercation, was shot and killed. The prosecution's theory was that the defendant was the shooter.In his appeal, the defendant argued that the court’s decision in a prior case, Commonwealth v. Brown, which abolished felony-murder as an independent theory of liability for murder in the first and second degrees, should be applied to his case retroactively. He maintained that not doing so violated equal protection principles as more Black individuals were serving life sentences without parole for felony-murder than white individuals. However, the court rejected this argument, noting that the decision in Brown was applied to all equally, regardless of race or ethnicity.The defendant also claimed errors in jury instructions and conduct by the trial judge, but the court determined that there was no reversible error. Lastly, the defendant argued that he received ineffective assistance of counsel, but the court found that the decisions by the defense were not manifestly unreasonable. View "Commonwealth v. Shepherd" on Justia Law