Justia Civil Rights Opinion Summaries

Articles Posted in Massachusetts Supreme Judicial Court
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The Supreme Judicial Court reversed the order of the trial denying Defendant's motion to vacate global positioning system (GPS) monitoring as a condition of his probation, holding that the Commonwealth failed to establish how the imposition of GPS monitoring would further its interest in enforcing the court-ordered exclusion zone surrounding the victim's home.Defendant was convicted on two indictments charging him with rape and sentenced to a term of incarceration followed by probation. As a condition of probation, the judge ordered Defendant to submit to GPS monitoring pursuant to Mass. Gen. Laws ch. 265, 47. Defendant moved to vacate the condition of GPS monitoring on the ground that it constituted an unreasonable search. The trial judge denied the motion. The Supreme Judicial Court reversed, holding that the Commonwealth did not meet its burden of establishing the constitutionality of the warrantless search. View "Commonwealth v. Roderick" on Justia Law

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The Supreme Judicial Court vacated the order of the trial court denying Defendant's motion for a new trial, holding that Defendant received constitutionally ineffective assistance of counsel during trial and that remand to the superior court was required for Defendant to receive a new trial.After a jury trial, Defendant was convicted of murder in the first degree and firearm offenses. During the trial, defense counsel disclosed confidential information to the Commonwealth regarding the location of "key incriminating evidence." Defendant filed a motion for a new trial, alleging that he had received constitutionally ineffective assistance of counsel because he had not given his counsel his informed consent to disclose the information. The superior court denied the motion. The Supreme Judicial Court vacated the superior court's judgment, holding (1) because defense counsel did not present Defendant with any other option than disclosing the existence of the incriminating evidence Defendant's purported consent to the disclosure was neither adequately informed nor voluntary; and (2) because trial counsel mistakenly believed he had a duty to disclose the incriminating evidence and did not obtain Defendant's prior consent to making that disclosure, an actual conflict of interest existed rendering the representation constitutionally ineffective. View "Commonwealth v. Tate" on Justia Law

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The Supreme Judicial Court affirmed Defendant's convictions of murder in the first degree and unlawful possession of a firearm, holding that Defendant's arguments on appeal were without merit.Specifically, the Supreme Judicial Court held (1) there was no abuse of discretion in the trial judge's determination that the defense had not established a prima facie case of racial discrimination in jury selection; (2) there was no prejudicial error in the jury instructions; (3) the judge did not abuse her discretion in excusing a juror based on decades-old charges; (4) the prosecutor did not commit misconduct in this case; and (5) there was no error or other reason warranting relief under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Grier" on Justia Law

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The Supreme Judicial Court reversed the decision of the trial court convicting Defendant of operating a motor vehicle while under the influence of alcohol (OUI) and negligent operation of a motor vehicle, holding that the trial court erred in denying Defendant's motion to suppress.Defendant moved to suppress the results of a blood alcohol content (BAC) analysis conducted by a crime lab after the police obtained and executed a search warrant for Defendant's blood, arguing that he did not consent to having his blood tested. The trial judge denied the motion. The Supreme Judicial Court reversed, holding that, in a prosecution under 24(1)(a), where the Commonwealth wishes to have admitted BAC evidence arising from testing or analysis of a defendant's blood done "by or at the direction of" police, police must first obtain the defendant's consent to the "chemical test or analysis" of his blood that may result from such evidence, regardless of whomever first drew the blood. View "Commonwealth v. Moreau" on Justia Law

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The Supreme Judicial Court affirmed the judgment of a single justice of the court denying Plaintiff's emergency complaint for relief in the nature of mandamus, holding that the single justice neither erred nor abused his discretion in denying Plaintiff's request for mandamus relief.In her complaint, Plaintiff requested that the single justice compel the Secretary of Housing and Economic Development to award her certain benefits under the Emergency Rental Assistance Program and to help her locate a home with suitable accommodations under the Americans with Disabilities Act. The single justice denied the request without a hearing. The Supreme Judicial Court affirmed, holding that mandamus relief was not appropriate in this case. View "Linardon v. Secretary of Housing and Economic Development" on Justia Law

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The Supreme Judicial Court vacated the opinion of a panel of the appeals court affirming the probation violation hearing judge's ruling that Probationer had violated the terms of his probation by committing new crimes, revoking his probation, and sentencing him to a term of incarceration, holding that Probationer's inability to question his accuser violated his right to present a defense.The hearing justice revoked Probationer's probation on the basis of hearsay statements by the complainant, his former fiancee, who alleged that Probationer had repeatedly raped her over a period of four months when they were living together. On appeal, Probationer argued that his constitutional due process rights were violated because the complainant did not appear at the hearing to testify or to be cross-examined. The Supreme Judicial Court agreed, holding that precluding Probationer from calling the accuser as a witness at the hearing violated Probationer's due process right to present a defense. View "Commonwealth v. Costa" on Justia Law

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The Supreme Judicial Court affirmed the order of a judge of the superior court granting Defendant's motion to suppress evidence of a firearm discovered during what Defendant alleged was an unlawful patfrisk, holding that the motion to suppress was properly granted.The Commonwealth filed an interlocutory appeal challenging the grant of Defendant's motion to suppress, arguing that the officers' suspicion that Defendant was armed and dangerous was reasonable. The Supreme Judicial Court disagreed, holding (1) the motion judge properly found that Defendant's behavior did not create reasonable suspicion that he was armed and dangerous; and (2) Defendant's reactions to the traffic stop did not justify the subsequent patfrisk. View "Commonwealth v. Garner" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the single justice of the court granting in part Defendant's gatekeeper petition to appeal from the denial of his motion for a new trial and reversed the motion judge's denial of Defendant's motion, holding that the Commonwealth violated its obligation under Brady v. Maryland, 373 U.S. 83 (1963), and prejudiced Defendant.In 1986, Defendant was convicted of murder in the first degree. The Supreme Judicial Court affirmed the conviction on appeal. At issue before the Supreme Judicial Court was Defendant's second motion for a new trial, in which Defendant alleged that several pieces of evidence were not disclosed at his criminal trial. The motion judge denied the motion. The Supreme Judicial Court reversed, holding that Defendant established that the Commonwealth failed to disclose exculpatory evidence and that such nondisclosure was prejudicial. View "Commonwealth v. Pope" on Justia Law

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The Supreme Judicial Court affirmed Defendant's convictions for four counts of murder in the first degree on the theory of felony-murder and the order denying his motion for a new trial and declined to grant relief under Mass. Gen. Laws ch. 278, 33E, holding that Defendant was not entitled to relief on any of his allegations of error.Specifically, the Supreme Judicial Court held (1) the judge did not abuse his discretion in denying Defendant's motion for a new trial; (2) Defendant's trial counsel did not provide ineffective assistance of counsel; (3) Defendant's argument that exculpatory evidence pointed to another suspect was unavailing; (4) the prosecutor did not commit misconduct during closing arguments; and (5) the judge did not abuse his discretion in declining to strike a juror. View "Commonwealth v. Moore" on Justia Law

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The Supreme Judicial Court affirmed the judgment of a superior court judge denying the special motion to dismiss under Mass. Gen. Laws ch. 231, 59H, the anti-SLAPP statute, filed by Exxon Mobil Corporation in this civil enforcement action brought by the Attorney General, holding that the anti-SLAPP statute does not apply to civil enforcement actions by the Attorney General.The Attorney General brought this action against Exxon Mobil for various alleged violations of Mass. Gen. Laws ch. 93A based on the company's communications regarding the impact of climate change with investors and consumers. Exxon Mobil filed an anti-SLAPP motion, asserting that the action was motivated by its "petitioning" activity. The superior court judge denied the motion on the ground that at least some of the activity alleged in the complaint was not "petitioning" under the statute. The Supreme Judicial Court affirmed on an alternate ground, holding that Mass. Gen. Laws ch. 231, 59H does not apply to civil enforcement actions brought by the Attorney General. View "Commonwealth v. Exxon Mobil Corp." on Justia Law