Justia Civil Rights Opinion Summaries

The Supreme Judicial Court affirmed Defendant's convictions for murder in the first degree and other crimes, affirmed orders denying Defendant's pretrial and postconviction motions, and declined to grant extraordinary relief pursuant to Mass. Gen. Laws ch. 278, 33E, holding that no reversible error occurred in the proceedings below.Specifically, the Supreme Judicial Court held (1) the trial judge did not err in deciding not to instruct the jury on self defense; (2) although it was error to require that Defendant's testimony take narrative form without his attorney's express prior invocation of Mass. R. Prof. C. 3.3(e), there was no substantial likelihood of a miscarriage of justice arising out of this error; (3) the trial judge did not err in denying Defendant's pretrial motion to dismiss the indictments; and (4) the trial judge properly denied Defendant's pretrial motion to suppress certain statements he made to officers at the police station without the benefit of prior Miranda warnings. View "Commonwealth v. Miranda" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions for murder in the first degree and felony murder and declined to exercise its authority to reduce or set aside the murder verdict, holding that the record revealed no basis to support relief under Mass. Gen. Laws ch. 278, 33E.Specifically, the Supreme Judicial Court held (1) there was no error, constitutional or otherwise, regarding the manner in which defense counsel and the trial judge invoked Mass. R. Prof. C. 3.3 (e), as appearing in 471 Mass. 1416 (2015), and related procedures approved in Commonwealth v. Mitchell, 438 Mass. 535 (2003); (2) the trial court did not err by allowing the testimony of a substitute medical examiner; (3) the trial judge's failure to sever Defendant's trial from that of his codefendant did not result in prejudicial error; and (4) Defendant's conviction of and sentencing for both felony-murder, with attempted armed robbery as the predicate felony, and armed assault with the intent to rob did not violate the double jeopardy clause of the Fifth Amendment. View "Commonwealth v. Leiva" on Justia Law

The Supreme Judicial Court affirmed Defendants' convictions and the orders denying their motions for a new trial and for postconviction relief but remanded the matter of Sheldon Mattis's sentence for an evidentiary hearing, holding that the record was insufficient to address the issue of whether a term of life without the possibility of parole for an individual between the age of eighteen and twenty-two years old violates the prohibition against cruel or unusual punishment.Defendants, Nyasani Watt and Sheldon Mattis, were convicted of murder in the first degree and related crimes. In addition to other claims, Mattis appealed from his mandatory sentence of life without the possibility of parole, arguing that, due to his age of eighteen, the sentence was unconstitutional. The Supreme Judicial Court held (1) there was no prejudicial error in the trial judge's challenged evidentiary rulings; (2) the judge did not err in failing to provide an involuntary manslaughter instruction; (3) remand was required for development of the record with regard to research on brain development after the age of seventeen; (4) the trial court did not err in denying Defendants' motions for a new trial; and (5) there was no reason to grant either defendant extraordinary relief pursuant to Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Watt" on Justia Law

In this case brought by incarcerated individuals challenging the conditions of confinement during the COVID-19 pandemic the Supreme Judicial Court allowed the parole board's motion to dismiss only with respect to the claims of the individuals civilly committed and allowed the Governor's motion to dismiss, holding that the Governor was not liable under the facts alleged.The complaint alleged that by confining Plaintiffs under conditions that put them in grave and imminent danger of contracting the COVID-19 virus and by failing to reduce the incarcerated population, Defendants were violating Plaintiffs' right to be free from cruel and unusual punishment and their right to substantive due process. Further, Plaintiffs alleged that confining persons who have been civilly committed under Mass. Gen. Laws ch. 123, 35 in correction facilities violates the individuals' rights to substantive due process. The Supreme Judicial Court (1) granted the Governor's motion to dismiss, holding that the Governor's presence was not necessary to provide any relief that a court may order in this case; and (2) allowed the parole board's motion to dismiss only with respect to the claims of individuals civilly committed, holding that if Plaintiffs' constitutional claims were to prevail, the parole board would be a logical and necessary party to accomplish a reasonable remedial process. View "Foster v. Commissioner of Correction (No. 2)" on Justia Law

The Supreme Judicial Court denied Plaintiffs' motion for a preliminary injunction enjoining the Department of Correction (DOC) from housing prisoners in facilities where the population exceeds its design-rated capacity and from housing prisoners areas where they must live within six feet of another person, holding that, despite the COVID-19 pandemic, Plaintiffs were unlikely to succeed on the merits of their claim for violations of the Eighth Amendment.Plaintiffs, incarcerated inmates serving sentences or individuals who were civilly committed under Mass. Gen. Laws ch. 123, 35, commenced a class action alleging that their conditions of confinement exposed them to unreasonable risks from the COVID-19 pandemic. Specifically, Plaintiffs alleged that Defendants' failure to take steps to reduce the incarcerated population so as to permit adequate physical distancing constituted cruel and unusual punishment in violation of the Eighth Amendment and violated substantive due process requirements. Plaintiffs sought a preliminary injunction in their claims for unconstitutional conditions of confinement because of the risk of a disease. The Supreme Judicial Court denied the motion, holding that Plaintiffs were unlikely to succeed on the merits of their claim. The Court then transferred the case to the superior court for a final adjudication on the merits. View "Foster v. Commissioner of Correction (No. 1)" on Justia Law

The Supreme Judicial Court vacated certain portions of a trial judge's nondisparagement orders issued to the parties in this case in an attempt to protect the psychological well-being of the parties' minor child, holding that the nondisparagement orders here operated as an impermissible prior restraint on speech.After Mother filed for divorce from Father, Mother filed a motion for temporary orders, including a request that the judge prohibit Father from posting disparaging remarks about her and the ongoing litigation on social media. The judge issued temporary orders that included nondisparagement provisions against both parties. Thereafter, Mother filed a complaint for civil contempt alleging that Father violated the first order. A different judge declined to find contempt on the ground that the first order, as issued, constituted an unlawful prior restraint of speech in violation of Father's constitutional rights. The Supreme judicial Court agreed, holding that the nondisparagement orders were unconstitutional. View "Shak v. Shak" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree and the denial of his motion for a new trial and declined to exercise its authority under Mass. Gen. Laws ch. 278E to reduce Defendant's conviction to murder in the second degree, holding that Defendant was not entitled to relief on any of his allegations of error.Defendant was convicted of murder in the first degree on the theory of felony-murder. Defendant filed a motion for a new trial, which was denied. The Supreme Judicial Court affirmed, holding (1) Defendant's motion for a new trial was correctly denied because Defendant was not prejudiced by counsel's ineffective assistance; (2) this Court declines to extend the reach of the Court's holding in Commonwealth v. Brown, 477 Mass. 805 (2017), to Defendant's case; and (3) trial judge erred when he declined Defendant's request that the jury be instructed on the elements of voluntary and involuntary manslaughter, but the error was not prejudicial in the context of the judge's other instructions. View "Commonwealth v. Martin" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions and the decision of the Appeals Court denying Defendant's motion to vacate the entry of his appeal from his convictions in that court and to have the case entered directly in the Supreme Judicial Court, holding that a direct appeal from the third conviction of a habitual offender pursuant to Mass. Gen. Laws ch. 279, 25(b) may be entered in the Appeals Court.Defendant was indicted for serious felonies arising from a brutal attack and rape. In addition to charging the specific felony, each indictment also alleged that the sentence for that felony should be enhanced pursuant to the habitual criminal provision Mass. Gen. Laws ch. 279, 25(a) or the habitual offender provision of section 25(b), or both. After he was convicted, Defendant moved to have the case entered directly in the Supreme Judicial Court. The Appeals Court denied the motion. The Supreme Judicial Court affirmed Defendant's convictions, holding (1) this direct appeal was entitled to the unique review prescribed by Mass Gen. Laws ch. 278, 33E, and the Appeals Court may conduct such section 33E review; (2) Defendant was not impermissibly allowed to waive his right to a jury trial on the sentencing enhancement provisions of the indictments; and (3) Defendant was not entitled to reversal of his convictions on any other ground. View "Commonwealth v. Billingslea" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court denying Defendant's motions to suppress, holding that the limited use of automatic license plate readers (ALPRs) in this case did not implicate constitutional protections against unreasonable searches.While police were investigating Defendant on suspicion of drug distribution they used ALPRs on two bridges to track Defendant's movements. The police accessed historical data via ALPR technology and received real-time alerts, the last of which led to Defendant's arrest. Defendant filed motions to suppress the ALPR data and the fruits of the arrest. The superior court denied the motions. The Supreme Judicial Court affirmed, holding that while the widespread use of ALPRs in the Commonwealth could implicate a defendant's constitutional protected expectation of privacy in the whole of his public movements, that interest was not invaded by the limited extent and use of the ALPR data in the instant case. View "Commonwealth v. McCarthy" on Justia Law

The Supreme Judicial Court affirmed the order of the trial judge granting Defendant's motion to suppress certain GPS location data and its fruits, holding that the initial imposition of a GPS device as a condition of pretrial release violated article 14 of the Massachusetts Declaration of Rights.In 2015, Defendant was charged with possession of a class B substance with the intent to distribute, as a subsequent offense, and motor vehicle violations. Defendant was ordered to wear a GPS monitoring device as a condition of release. Defendant was later arrested and indicted on charges of armed robbery while masked. Defendant moved to suppress the GPS location data used to identify him as being present at the scene of the crime. After finding that Defendant had consented to the use of GPS location data only for the purposes of enforcing conditions of release and not for general law enforcement purposes the judge concluded that the search was not supported by probable cause and granted the motion to suppress. The Supreme Judicial Court affirmed on different grounds, holding that the search was impermissible because the GPS monitoring did not further any legitimate governmental interests. View "Commonwealth v. Norman" on Justia Law