Justia Civil Rights Opinion Summaries

The Supreme Judicial Court affirmed Defendant's convictions for murder in the first degree, armed assault with intent to murder, and animal cruelty, and declined to grant extraordinary relief under Mass. Gen. Laws ch. 278, 33E, holding that no prejudicial error occurred.Specifically, the Supreme Judicial Court held (1) no error occurred during jury selection with respect to the voir dire of prospective jurors; (2) the judge did not abuse her discretion in finding that the neutral reason provided by the prosecutor for exercising a peremptory challenge was genuine and adequate; (3) the judge did not abuse her discretion in admitting prior bad act evidence, testimony that Defendant had access to firearms, and testimony regarding the results of a criminalist's Internet search; (4) evidence of charred paper fragments found in the basement of the dwelling where Defendant lived was not relevant, but the error was not prejudicial; and (5) there was no error in the prosecutor's statements during closing argument. View "Commonwealth v. Mason" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction for murder in the first degree, holding that any claimed instructional errors did not give rise to a substantial likelihood of a miscarriage of justice and that Defendant did not receive ineffective assistance of counsel.On appeal, Defendant argued that the trial court erred by failing to instruct the jury concerning a lack of criminal responsibility and mental impairment and erred by failing properly to instruct the jury that they could consider evidence of intoxication when determining whether a murder was committed with extreme atrocity or cruelty. Defendant further argued that trial court's failure to remedy the instructional errors deprived him of the effective assistance of counsel. The Supreme Judicial Court affirmed, holding (1) there was no error in the jury instructions and, accordingly no substantial likelihood of a miscarriage of justice in counsel's handling of the instructions; and (2) there was no reason to reduce the verdict to one of murder in the second degree. View "Commonwealth v. Santiago" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction for murder in the first degree on a theory of extreme atrocity or cruelty, holding that the errors that occurred during the trial did not require a new trial.On appeal, Defendant argued that she was prejudiced from the Commonwealth's use of prior bad act evidence. The Supreme Judicial Court affirmed, holding (1) some of the challenged evidence should not have been admitted, but there was no abuse of discretion int he judge's conclusion that the probative value of the evidence was not outweighed by its prejudicial effect; (2) the prosecutor's reliance on the prior bad act evidence in closing arguments was improper, but the improprieties did not so infuse the trial with unfairness as to deny due process of law; and (3) a reduction in the verdict pursuant to Mass. Gen. Laws ch. 278, 33E would not serve the interests of justice. View "Commonwealth v. Peno" on Justia Law

The Supreme Judicial Court reversed the denial of the motions to suppress filed by Nelson Mora and Ricky Suarez, holding that the continuous, long-term pole camera surveillance targeted at the residences of Mora and Suarez was a search under article 14 of the Massachusetts Declaration of Rights.Using video footage collected by hidden video cameras on public telephone and electrical poles (pole cameras) the Commonwealth secured indictments against twelve defendants, including Mora and Suarez. Eight defendants moved to suppress the pole camera footage and evidence derived from that footage as the fruits of an unreasonable search. The superior court denied the motions, concluding that the pole camera surveillance did not constitute a search. The Supreme Judicial Court reversed as to Mora and Suarez and remanded the matter to the superior court for further proceedings, holding that the warrantless surveillance of Mora's and Suarez's residences for more than two months was a "search" under article 14. View "Commonwealth v. Mora" on Justia Law

The Supreme Judicial Court affirmed the order of the single justice denying Plaintiff's motion asking the single justice to find Defendants and the superior court in contempt of a Mass. Gen. Laws ch. 211, 4A transfer order, holding that there was no error or abuse of discretion in denying the motion for contempt.Plaintiff filed a complaint in the county court seeking declaratory and injunctive relief and damages against the Boston Housing Authority (BHA) and the United States Department of Housing and Urban Development (HUD) based on a claim of housing discrimination. The single justice transferred the complaint to the superior court pursuant to Mass. Gen. Laws ch. 211, 4A. From there, the case was removed to the federal court. The federal court dismissed the claims against HUD and remanded the claims against the BHA to the superior court. Plaintiff then filed a motion in the county court asking the single justice to find Defendants and the superior court in contempt of the transfer order. The single justice denied the motion without a hearing. The Supreme Judicial Court affirmed, holding that the single justice correctly denied the motion for contempt. View "Linardon v. United States Department of Housing & Urban Development" on Justia Law

The Supreme Judicial Court reversed the order of the superior court judge allowing Defendant's motion to suppress statements he made to police officers, holding that Defendant was not subjected to custodial interrogation while speaking with the police officers and that the statements were otherwise voluntary.Defendant was placed under arrest for the removal of human remains from the Worcester cemetery. Defendant filed a motion to suppress statements he made to Hartford police officers, arguing that the statements were made under custodial interrogation without Miranda warnings and that they were involuntary. The motion judge allowed the motion to suppress. The Supreme Judicial Court reversed, holding (1) Defendant was not in custody when he made his statements to the police officers, and therefore, Miranda warnings were not required; and (2) there was no indication that Defendant's statements were involuntarily made. View "Commonwealth v. Medina" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction for murder in the first degree, holding that there was no prejudicial error in the proceedings below, and there was no reason for the Court to exercise its authority under Mass. Gen. Laws ch. 278, 33E to reduce the verdict or to order a new trial.Specifically, the Supreme Judicial Court held (1) the motion judge did not err in denying Defendant's motion to suppress his statement to the police; (2) an indisputably gruesome photograph should not have been admitted into evidence, but there was no cause to disturb the verdict; (3) there was no error in the absence of a sua sponte instruction on lost evidence; (4) the judge did not err in admitting into evidence two knives; (5) certain statements in the prosecutor's closing argument were improper, but the improprieties did not require a new trial; and (6) there were no grounds on which to reduce the degree of guilt or to order a new trial. View "Commonwealth v. Walters" on Justia Law

The Supreme Judicial Court vacated Defendant's conviction for kidnapping but affirmed all other convictions, holding that the verdicts of murder in the first degree were consonant with justice but that Defendant's kidnapping conviction must be vacated because it was based on an inveiglement theory previously dismissed by the motion judge.Defendant was found guilty of three counts of murder in the first degree, kidnapping, and witness intimidation. On appeal, Defendant argued, among other things, that his conviction of kidnapping based on a 2010 incident must be vacated because the theory of kidnapping was invalid or foreclosed by the superior court judge's ruling on a pretrial motion to dismiss. The Supreme Judicial Court agreed, holding (1) Defendant's 2010 kidnapping conviction must be reversed, as the theory on which the prosecution proceeded at trial had previously been dismissed by the court; (2) Defendant was not entitled to relief on his remaining allegations of error; and (3) there is no reason for this Court to exercise its authority under Mass. Gen. Laws ch. 278, 33E to order a new trial or direct the entry of verdicts of a lesser degree of guilt. View "Commonwealth v. Hall" on Justia Law

The Supreme Judicial Court held that Defendant's right to choice of private counsel and right to be present during a critical stage of the proceedings under both the federal and state constitutions were violated during his criminal trial, requiring automatic reversal absent waiver, but that the delay of more than thirty years in bringing these claims under these circumstances waived the claims under state and federal constitutional law.In 1982, Defendant was convicted of murder in the first degree. In 2015, Defendant filed a second motion for a new trial asserting that the appointment of his court-appointed, State-funded counsel violated his rights under the Sixth Amendment and article 12 of the Massachusetts Declaration of Rights. The Supreme Judicial Court held (1) Defendant's right to choice of private counsel and right to be present during a critical stage of the proceedings under both the federal and state constitutions were violated, and these violations were structural errors; (2) the delay in bringing these claims combined with the fact that the transcript clearly depicting the constitutional violations was available for Defendant in 1991 and for the public defense counsel screening his claims in 1992-1993 and 2000 waived Defendant's claims; and (3) there was no substantial risk of a miscarriage of justice. View "Commonwealth v. Francis" on Justia Law

The Supreme Judicial Court affirmed the judgment of the single justice denying, without a hearing, Defendant's petition for relief under Mass. Gen. Laws ch. 211, 3, holding that the single justice neither erred nor abused his discretion by denying relief.After Defendant's motion to suppress was allowed, the Commonwealth applied for leave to prosecute an interlocutory appeal. A single justice allowed the application and directed the appeal to the Appeals Court. An interlocutory appeal was entered more than a year after the single justice granted the Commonwealth leave to appeal. Defendant filed a motion to dismiss the underlying charges, arguing that his speedy trial and due process rights had been violated. The motion was denied. Defendant then filed his Mass. Gen. Laws ch. 211, 3 petition seeking leave to cross-appeal from the denial of his motion to dismiss. The single justice denied relief. The Supreme Court affirmed, holding that Defendant did not show that the ordinary process of trial and appeal was inadequate for him to obtain review of his speedy trial and due process claims. View "Ramos v. Commonwealth" on Justia Law