Justia Civil Rights Opinion Summaries

The Supreme Judicial Court affirmed Defendant's convictions for two counts of murder in the first degree and the denial of his motion for a new trial, holding that Defendant was not deprived of his constitutional right to the effective assistance of counsel.On appeal, Defendant argued, among other things, that it was manifestly unreasonable for his trial counsel to forgo mental health defenses in favor of a third-party culprit defense. The Supreme Judicial Court disagreed, holding (1) trial counsel was not ineffective for urging one defense over the other, and Defendant was not prejudiced by his trial counsel's performance; and (2) there was no basis upon which to exercise the Court's extraordinary authority to order a new trial or to reduce the verdicts pursuant to Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Velez" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on theories of both deliberate premeditation and extreme atrocity or cruelty, holding that there was no reversible error either in any issue raised by Defendant or in this Court's review under Mass. Gen. Laws ch. 33E.Specifically, the Supreme Judicial Court held (1) the trial court did not err in denying Defendant's motion to suppress handwritten note and oral statements he made to officers while he was hospitalized; (2) Defendant was not entitled to reversal of his convictions on the grounds of error in the trial judge's evidentiary rulings; (3) the trial judge did not err in denying Defendant's motion for a new trial; and (4) there was no basis for reducing Defendant's sentence on the murder conviction or ordering a new trial. View "Commonwealth v. Welch" on Justia Law

The Supreme Judicial Court affirmed the allowance of Defendant's motion for a new trial, holding that the evidence supporting the charge of armed home invasion was insufficient to allow a finding beyond a reasonable doubt on each element of the offense.Defendant was convicted of armed home invasion, armed burglary, robbery while armed and masked, and other charges. Defendant later filed a motion for a new trial on the charge of armed home invasion, arguing that there was insufficient evidence that he was armed when he entered the building. The superior court allowed the motion. The Supreme Judicial Court affirmed and vacated and set aside Defendant's conviction of armed home invasion, holding that because there was no evidence that Defendant armed himself with a weapon before he entered the building, he could not be convicted of armed home invasion. The Court remanded the matter to the superior court for reconsideration of the sentencing scheme on the remaining convictions. View "Commonwealth v. Tinsley" on Justia Law

The Supreme Judicial Court reversed the order of the trial judge denying Defendant's motion to continue his evidentiary hearing on his motion to suppress until it could be held in person, holding that the trial judge abused her discretion.Defendant, who was charged with a drug offense, filed a motion to suppress evidence and statements. After the suppression hearing was postponed for a third time because of the COVID-19 pandemic the judge ordered that the hearing take place via Zoom. Defendant filed a motion objecting to the Zoom hearing and requested that the case be continued until an in-court hearing could be held safely. The judge denied the motion. The Supreme Judicial Court reversed, holding that because Defendant waived his right to a speedy trial and there were no civilian victims or witnesses, the trial judge abused her discretion in denying Defendant's objection to conducting the evidentiary hearing on his motion to suppress via Zoom video conference. View "Diaz v. Commonwealth" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on a theory of extreme atrocity or cruelty, holding that there was no error that would require reversal of Defendant's convictions.Defendant's first trial ended in a mistrial because the jury were unable to reach a verdict. After a retrial, Defendant was convicted of murder. On appeal, Defendant challenged the trial court's denial of his motion to suppress his cell site location information (CSLI) and any "fruits" derived from it. The Supreme Judicial Court affirmed, holding (1) law enforcement infringed upon Defendant's reasonable expectation of privacy in his CSLI without a warrant, but the error was harmless; (2) trial counsel was not ineffective for failing to instruction to certain portions of the jury instructions; and (3) Defendant was not entitled to relief on his remaining claims of error. View "Commonwealth v. Gumkowski" on Justia Law

The Supreme Judicial Court reversed Defendant's conviction of two counts of assault and battery by means of a dangerous weapon resulting in serious injury, holding that the trial court judge erred in excluding one of Defendant's experts, and this error was prejudicial.At trial, Defendant argued that he acted in self-defense and that the two men involved in the altercation were motivated to attack him by racial animus. To support his theory, Defendant sought to introduce the testimony of two experts who would testify that the tattoo found on one of the men was affiliated with a group that espoused white supremacist beliefs. The judge excluded both efforts on reliability grounds. The Supreme Judicial Court reversed and remanded the case for a new trial, holding that the trial judge abused his discretion in excluding the testimony of one of the experts, and this error was prejudicial. View "Commonwealth v. Hinds" on Justia Law

The Supreme Judicial Court affirmed the judgment of the single justice denying Petitioner's petition filed pursuant to Mass. Gen. Laws, ch. 211, 3, holding that the single justice did not err or abuse his discretion in denying relief.Petitioner was charged with trafficking in heroin, operating a motor vehicle with a suspended license, and two civil motor vehicle infractions. Petitioner filed a motion to suppress, which was denied. Petitioner subsequently filed a motion for leave to file a renewed motion to suppress, as well as a motion for recusal of the district court judge. The judge denied both motions. Petitioner then filed his Mass. Gen. Laws ch. 211, 3 petition arguing that the trial judge made multiple decisions that were unfairly prejudicial to him. The single justice denied relief. The Supreme Judicial Court affirmed, holding that there was nothing exceptional about Petitioner's case that warranted the exercise of this Court's extraordinary power. View "Torres v. Commonwealth" on Justia Law

The Supreme Judicial Court remanded this matter to the county court for entry of a judgment allowing Defendant's petition pursuant to Mass. Gen. Laws ch. 211, 3 and ordering that the superior court judge's order hospitalizing Defendant under Mass. Gen. Laws ch. 123, 16(a) be vacated, holding that Defendant's substantive due process rights were violated.A grand jury returned a twelve-count indictment charging Defendant with two counts of armed carjacking and multiple related charges. After a jury-waived trial, Defendant was found not criminally responsible by reason of mental illness. Thereafter, the judge granted the Commonwealth's motion to hospitalize Defendant for evaluation pursuant to section 16(a) for forty days. Defendant filed a petition pursuant to section 3 requesting relief from confinement. A single justice denied the petition. The Supreme Judicial Court remanded the matter, holding that there was no constitutionally adequate justification to temporarily commit Defendant under section 16(a). View "Garcia v. Commonwealth" on Justia Law

The Supreme Judicial Court held that the ministerial exception did not apply to Plaintiff, an associate professor of social work at a private Christian liberal arts college, and therefore, the superior court judge did not err in dismissing on summary judgment Gordon College's affirmative defense of the ministerial exception in this retaliation complaint.The ministerial exception prohibits government interference with employment relationships between religious institutions and their ministerial employees. Plaintiff, a tenured associate professor of social work at Gordon, alleged that Defendants - Gordon and its president and provost (collectively, Gordon) - unlawfully retaliated against her for her opposition to Gordon's policies and practices regarding LGBTQ+ individuals. The parties cross-moved for summary judgment on the question of whether the ministerial exception barred Plaintiff's claims. The superior court allowed Plaintiff's motion but denied Gordon's, concluding that Gordon was a religious institution but that Plaintiff was not a ministerial employee. The Supreme Judicial Court affirmed, holding that the superior court judge did not err in dismissing the affirmative defense of the ministerial exception. View "DeWeese-Boyd v. Gordon College" on Justia Law

The Supreme Judicial Court affirmed the underlying judgment of the Housing Court in this summary process eviction action awarding possession to Landlord, holding that Tenant's appeals regarding his requests for disabilities accommodations in the Appeals Court and in the single justice session were moot.After a bench trial the Housing Court judge awarded possession to Landlord but granted Tenant a reasonable accommodation in the form of a limited stay of execution. On appeal, Tenant requested disabilities accommodations from the Appeals Court, some of which were granted. Tenant also filed a petition in the county court pursuant to Mass. Gen. Laws ch. 211, 3, which a single justice denied. The appeals were consolidated. The Supreme Judicial Court affirmed, holding that Tenant's claims arising from the denial of requested disabilities accommodations in the Appeals Court and in the single justice session of this Court were moot. View "Saipe v. Sullivan & Co., Inc." on Justia Law