Justia Civil Rights Opinion Summaries

The Supreme Judicial Court held that the Civil Defense Act (CDA), Mass. Gen. Laws ch. 17, 2A, provided the Governor with the authority for his March 10, 2020 declaration of a state of emergency in response to the COVID-19 pandemic and for his issuance of the emergency orders and that the emergency orders did not violate article 30 of the Massachusetts Declaration of Rights or Plaintiffs' federal or state constitutional rights to procedural and substantive due process or free assembly.Plaintiffs brought this complaint seeking declaratory judgment and injunctive relief, challenging the Governor's declaration of a state of emergency and the emergency orders placing restrictions on daily activities as unauthorized and unconstitutional. The Supreme Judicial Court denied relief, holding that Plaintiffs' claims were unavailing and that the emergency orders were authorized and constitutional. View "Desrosiers v. The Governor" on Justia Law

The Supreme Court affirmed the judgment of the single justice denying Defendant's petition filed pursuant to Mass. Gen. Laws ch. 211, 3 seeking to remove the conditions of GPS monitoring and home confinement on Defendant's release, holding that the conditions were constitutional.Defendant was convicted of trafficking narcotics. Defendant filed a motion for a new trial and sought to stay the execution of her sentence while her motion was pending. The trial judge granted the stay and imposed the conditions of release at issue. Defendant then filed a petition in the county court seeking relief from the conditions. The single justice denied relief. The Supreme Judicial Court affirmed, holding (1) the condition of home confinement was not a seizure because it was imposed pursuant to a valid conviction and lawful sentence; and (2) the imposition of GPS monitoring was a search, but it was reasonable under the circumstances. View "Garcia v. Commonwealth" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree, assault and battery by means of a dangerous weapon, and improper disposition of a human body, holding that there was no prejudicial error in the proceedings below.On appeal, Defendant argued that the trial court erred in denying his motion to suppress his cell site information (CSLI) because it was obtained by police without a warrant and that a subsequent search pursuant to a warrant for the same information was tainted by the initial warrantless search. The Supreme Judicial Court disagreed, holding (1) the trial judge did not err in failing to suppress Defendant's CSLI, and the motion judge did not err in denying Defendant's motion for a new trial and for an evidentiary hearing on this same basis; (2) trial counsel's failure to move to suppress the fruits of the initial illegal search did not result in a substantial likelihood of a miscarriage of justice; and (3) there was no reason to grant a new trial or set aside the jury's verdict under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Wilson" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on the theory of felony murder, with armed robbery as the predicate felony, holding that there was no prejudicial error in the proceedings below.Specifically, the Supreme Judicial Court held (1) the trial judge did not err by not providing, sua sponte, an instruction on felony murder in the second degree; (2) the admission of Defendant's cell site location information did not result in a substantial likelihood of a miscarriage of justice; (3) the trial judge did not err in denying Defendant's motion to admit privileged psychiatric records; (4) there was no prejudicial error in the judge's decision prohibiting Defendant from eliciting certain testimony as hearsay on cross-examination; (5) the judge did not err in instructing the jury on inferences; (6) trial counsel provided effective assistance; and (7) there was no reason for the Court to exercise its authority under Mass. Gen. Laws ch. 278, 33E to reduce Defendant's verdict or order a new trial. View "Commonwealth v. Chesko" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions for murder in the first degree on a theory of deliberate premeditation and unlawful possession of a firearm, holding that there was no prejudicial error in the proceedings below.On appeal, Defendant argued that his trial counsel provided ineffective assistance, that the judge erred in allowing the introduction of certain evidence, and that the judge abused his discretion in allowing the prosecutor to exercise a peremptory challenge. The Supreme Judicial Court affirmed, holding (1) Defendant did not receive ineffective assistance of counsel; (2) there was no reversible error from the admission of the challenged evidence; (3) there was no abuse of discretion in the judge's finding that Defendant did not establish a prima facie case of excluding black jurors; and (4) there was no basis for the Court to exercise its authority under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Henderson" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree, holding that Defendant failed to demonstrate that his trial counsel was ineffective and that the trial court did not err in denying Defendant's motion for a new trial.In this appeal, which the Supreme Court consolidated with the denial of Defendant's motion for a new trial, Defendant argued that his trial counsel was ineffective for not moving to suppress his optical records and his cell site location information. The Supreme Court affirmed, holding (1) Defendant's trial counsel provided effective assistance; (2) the trial court did not err in denying Defendant's motion for a new trial; and (3) there was no reason to vacate Defendant's conviction or to order a new trial pursuant to Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Gosselin" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions of two counts of murder and other crimes, holding that any error committed during the proceedings below was not prejudicial.Specifically, the Supreme Judicial Court held (1) the trial judge's admission of a DNA expert's testimony regarding a "nonexclusion" result; (2) the trial judge did not err in admitting into evidence charts depicting DNA test results; (3) the prosecutor erred in misstating certain evidence, but the error was not prejudicial; (4) the judge's jury instruction that prior inconsistent statements may not be considered substantively was erroneous, but the error did not prejudice Defendant as to require a new trial; (5) the trial judge did not err in denying Defendant's motion for a new trial on the grounds that a purported courtroom closure during voir dire was unconstitutional; and (6) following plenary review of the record pursuant to Mass. Gen. Laws ch. 278, § 33E, there was no basis for reducing Defendant's sentence on the murder conviction or ordering a new trial. View "Commonwealth v. Lester" on Justia Law

The Supreme Judicial Court vacated Defendant's convictions for operating a motor vehicle while under the influence of alcohol (OUI) causing serious bodily injury and misleading an investigator, holding that errors at trial required that Defendant's convictions be vacated and the matter remanded for a retrial.Specifically, the Supreme Judicial Court held (1) the plain language of the relevant statutes makes clear that blood alcohol level testing shall not be done absent consent, and any nonconsensual testing done at the police's direction is inadmissible; (2) because Defendant's blood draw was performed without Defendant's actual consent, the blood draw was impermissible and the blood alcohol content test results were improperly admitted at trial, and the tainted evidence was not harmless beyond a reasonable doubt; and (3) the trial judge erred by failing to make an independent determination regarding the voluntariness of Defendant's statements and by failing to give a humane practice instruction to the jury, and the error created a substantial risk of a miscarriage of justice. View "Commonwealth v. Bohigian" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree, holding that there was no reversible error in the proceedings below nor reason to exercise the Court's authority under Mass. Gen. Laws ch. 278, 33E.Specifically, the Supreme Judicial Court held (1) the Commonwealth did not violate Defendant's due process rights by omitting evidence that helped Defendant and that countered the prosecutor's theory of the case; (2) error occurred when a lay witness testified that he had previously referred to Defendant as the "guy...who killed my cousin" but the inadmissible evidence did not create a substantial likelihood of a miscarriage of justice; (3) the prosecutor improperly urged the jury to draw an inference of guilt against Defendant due to his courtroom behavior, but the error did not create a substantial likelihood of a miscarriage of justice; (4) there was no error in the jury instructions regarding circumstantial evidence; (5) Defendant's trial counsel did not provide ineffective assistance; and (6) the motion judges did not err in denying the defendant's motions for posttrial discovery. View "Commonwealth v. Moffat" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on a theory of deliberate premeditation and an attempt to suborn perjury and declined to exercise its extraordinary authority under Mass. Gen. Laws ch. 278, 33 E to order a new trial or to reduce the degree of guilt, holding that no prejudicial error occurred in the proceedings below.Specifically, the Supreme Judicial Court held (1) the evidence was sufficient to support Defendant's conviction; (2) the trial court did not err in denying Defendant's motion to suppress cell site location data and admitting that data at trial; (3) the trial judge did not abuse his discretion in allowing into evidence out-of-court statements by Defendant's alleged coventurer and in excluding other evidence concerning that coventurer; (4) the trial judge did not abuse his discretion by allowing the charges against Defendant to be joined for trial; (5) the trial judge did not commit prejudicial error by not giving "missing witness" and Bowden instructions; and (6) improprieties in the prosecutor's closing argument did not create a substantial likelihood of a miscarriage of justice. In addition, the Supreme Judicial Court discerned no reason to order a new trial or to reduce the degree of guilt under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Wilkerson" on Justia Law