Justia Civil Rights Opinion Summaries

In a case before the Supreme Judicial Court of Massachusetts, the defendant, Denzel McFarlane, convicted of unlawful possession of a firearm and other related charges, appealed for a new trial. He based his appeal on the fact that a police officer who had arrested and testified against him was found civilly liable for false arrest and false imprisonment in an unrelated lawsuit. McFarlane argued that the existence of the civil lawsuit against the officer was exculpatory information that the prosecution should have disclosed to the defense but failed to do so.The primary legal issue was whether the existence of a pending civil lawsuit against a police officer must be disclosed by a prosecutor as exculpatory evidence. The court held that the existence of a pending civil lawsuit against a police officer does not need to be disclosed by a prosecutor as exculpatory evidence. The court reasoned that until a finding of liability has been made, a pending civil lawsuit constitutes an unsubstantiated allegation of police misconduct that does not tend to negate the guilt of the defendant. Therefore, the court affirmed the denial of McFarlane's motion for a new trial.In addition, the court established that while a prosecutor has no duty to inquire into pending civil lawsuits against a prosecution team member, the duty of inquiry does require that prosecutors inquire about the existence of any findings of civil liability related to the performance of a police officer's duties. In other words, if a police officer has been found liable in a civil lawsuit, the prosecution has a duty to discover that information and potentially disclose it to the defense. View "Commonwealth v. Mcfarlane" on Justia Law

In this case, six plaintiffs -- two criminal defense organizations, two defense attorneys, and two former criminal defendants -- filed a petition against the District Attorney's Office for the Hampden District in Massachusetts. The plaintiffs alleged multiple failures by the District Attorney's Office, primarily stemming from its handling of evidence of misconduct within the Springfield Police Department (the department). The U.S. Department of Justice had previously conducted an investigation and found that officers in the department, particularly those within the narcotics bureau, routinely falsified police reports and engaged in a pattern of excessive force.The Supreme Judicial Court of Massachusetts found that the District Attorney's Office, through certain discovery policies, committed a breach of both the duty to disclose evidence that tends to exculpate defendants and the duty to investigate or inquire about such evidence. Specifically, the court identified three problematic practices: 1) disclosing adverse credibility findings made about the department's officers only on a discretionary basis; 2) withholding instances of officer misconduct from disclosure where a specific bad act cannot be clearly attributed to a particular officer; and 3) failing to gain access to all documents known to have been reviewed by the Department of Justice (DOJ).To rectify these breaches, the court ordered the District Attorney's Office to obtain access to all categories of documents known to have been reviewed by the DOJ and disclose them to the plaintiffs. From there, case-by-case adjudication can begin to address the claims of individual defendants affected by the department's misconduct. In issuing this order, the court emphasized the importance of a prosecutor's dual duties -- to disclose and to investigate -- in upholding the integrity of the criminal justice system. View "Graham v. District Attorney for the Hampden District" on Justia Law

In the case at hand, the plaintiff, a civilly committed sexually dangerous person, petitioned the Department of Correction (DOC) for medical parole due to his deteriorating health conditions. The DOC denied his petition based on their policy that civilly committed individuals are ineligible for medical parole under G. L. c. 127, § 119A. The plaintiff sought review of this denial, arguing that his due process rights had been violated. A Superior Court judge allowed his motion for judgment on the pleadings and ordered the DOC to conduct a hearing on the plaintiff's medical parole petition.However, the Supreme Judicial Court of Massachusetts reversed the judge's order. The court held that the medical parole statute applies only to committed offenders serving a criminal sentence, not to civilly committed sexually dangerous persons. It further held that sexually dangerous persons may seek release due to terminal illness or physical or mental incapacity under G. L. c. 123A, § 9, and denying them an additional avenue for relief by means of the medical parole statute does not offend substantive due process. The Court concluded that the plaintiff's due process rights were not violated by the DOC's policy that precludes civilly committed sexually dangerous persons from eligibility for medical parole. View "Murphy v. Commissioner of Correction" on Justia Law

In the case at hand, the defendant, Joshua Hart, and his girlfriend, Brittany Smith, entered the home of an elderly couple, Thomas Harty and his wife, Joanna Fisher, intending to steal their car and money. The couple ended up fatally attacking both Harty and Fisher, and then fled the state in the victims' vehicle. Hart was convicted on two counts of first-degree murder, and he appealed on several grounds.Hart argued that his confession to law enforcement was involuntary and should have been suppressed, but the Supreme Judicial Court of Massachusetts disagreed. The court found that Hart's confession was voluntary based on the circumstances of the interrogation, his experience with the criminal justice system, and his own actions and statements during the interrogation.Hart also argued that the trial should have been moved to another venue due to pretrial publicity. The court disagreed, stating that the defendant did not provide sufficient evidence to demonstrate that the pretrial publicity caused either presumptive or actual prejudice. The court found that less than 20% of potential jurors were excused due to pretrial publicity, and the judge took extensive steps to protect Hart's right to a fair trial.Hart further contended that a statement made by the deceased victim, Fisher, to her nurse, which was relayed to the jury through the nurse's testimony, should have been excluded from evidence as it was hearsay and violated his right to confront witnesses. The court determined that Fisher's statements were non-testimonial and thus did not violate the confrontation clause. The court also found that even if Fisher's statements were admitted in error, there was no prejudice because the Commonwealth presented other compelling evidence of the facts relayed in Fisher's statements.Finally, Hart argued that his sentences of life without the possibility of parole constituted cruel or unusual punishment because he was under 25 years old at the time of the crimes. The court rejected this argument, finding no reason to extend the prohibition of life sentences without parole for juveniles to individuals under the age of 25.Accordingly, the court affirmed Hart's convictions. View "Commonwealth v. Hart" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions for murder in the first degree based on a theory of felony-murder, among other charges, holding that a police officer's identification testimony was admitted improperly, but its admission did not prejudice Defendant.On appeal, Defendant challenged the denial of his motion to suppress, among numerous other allegations of error. For the claimed errors, Defendant requested that the court reduce his verdict or order a retrial. The Supreme Judicial Court affirmed, holding (1) a police officer's testimony identifying Defendant in a video recording at trial was improperly admitted, but the admission did not prejudice Defendant; and (2) Defendant was not entitled to relief on his remaining allegations of error. View "Commonwealth v. Fisher" on Justia Law

In this case involving a facility that operated under the protection of a thirty-six-year-old consent decree the Supreme Judicial Court held that the trial judge did not abuse her discretion in concluding that the Department of Developmental Services failed to establish that the consent decree should be terminated based on the evidentiary record before the probate court.In question was the treatment and welfare of individuals who suffered from severe developmental and intellectual disabilities that caused them to engage in grievous self-harm and other life-threatening behaviors. The individuals lived in group homes under the care of Judge Rotenberg Educational Center, Inc. (JRC), a facility that employed the use of aversive interventions such as electric skin shock as part of its treatment approach. In the 1980s and 1990s State agencies disrupted JRC's operations, after which the consent decree was issued. Years later, the agencies bound by the decree moved for its termination, but the probate and family court denied the motion. The Supreme Judicial Court affirmed, holding that the Department's arguments against continued enforcement of the consent decree were unavailing. View "Judge Rotenberg Educational Center, Inc. v. Commissioner of Dep't of Developmental Services" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of assault and battery by means of a dangerous weapon, holding that portions of the victim's then-girlfriend's grand jury testimony were properly admitted in accordance with the hearsay exemption for prior inconsistent statements.Prior to trial, the victim's then-girlfriend Shyla Bizarro identified Defendant as the victim's attacker from surveillance video footage and testified to her identification before the grand jury. Prior to her testimony, however, Bizarro revealed that she wished to recant her statements to police and her grand jury testimony. The trial judge admitted substantively the recanted portions of Bizarro's grand jury testimony, including her prior statements of identification. The Supreme Judicial Court affirmed the conviction, holding (1) the portions of Bizarro's grand jury testimony were properly admitted as prior inconsistent statements; (2) portions of Bizarro's grand jury testimony identifying Defendant in the video independently satisfied the hearsay exemption for statements of identification; and (3) there was no merit to Defendant's remaining arguments. View "Commonwealth v. Brum" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court denying Defendant's motion for a new trial following his successful motion for postconviction forensic and deoxyribonucleic acid (DNA) analysis pursuant to Mass. Gen. Laws ch. 278A, 2, holding that there was no error in the denial of Defendant's motion for a new trial.A jury convicted Defendant of murder in the first degree on a theory of extreme cruelty or atrocity, and the Supreme Court affirmed. Following multiple pro se motions, Defendant filed the instant motion for postconviction DNA analysis, which the court allowed. Defendant then filed a motion for a new trial. The motion judge denied the motion, concluding that the new evidence did not case real doubt on the justice of Defendant's conviction. Defendant then filed a petition pursuant to Mass. Gen. Laws ch. 278, 33E for leave to appeal. A single justice granted the petition. The Supreme Judicial Court affirmed the denial of Defendant's motion for a new trial, holding that Defendant was not entitled to relief on his allegations of error. View "Commonwealth v. Duguay" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions other than his unlawful possession conviction, which the Court vacated in light of its recent opinion in Commonwealth v. Guardado, 491 Mass. 666 (2023), holding that Defendant's rights under the Second Amendment and his due process rights were violated as to this conviction because the jury was not instructed that licensure was an essential element of the crime.Specifically, the Supreme Judicial Court held (1) the trial court did not err in denying Defendant's motion to suppress his statement at the police station on the grounds that police officers impermissibly recorded it without his express consent and that he was not informed promptly of his right to make a telephone call; (2) the prosecutor did not improperly refer to omissions in Defendant's statement to police officers; (3) there was no reason to reduce the degree of guilt or order a new trial; and (4) in light of this Court's recent opinion in Guardado, Defendant's unlawful possession of a firearm conviction must be vacated. View "Commonwealth v. Morris" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions for murder in the first degree for the killing of Brandy Waryasz on theories of premeditation and felony-murder and murder in the first degree for the killing of Dane Anthony Hall, on a theory of felony-murder, but reversed his conviction for armed robbery, holding that the conviction must be dismissed as duplicative of the felony-murder conviction.Defendant attacked Waryasz while she was working at a gas station by tightly wrapping a ligature around her neck. Waryasz, who was seven months pregnant with Hall, died from a constricted airflow, killing her son within minutes of his mother. Defendant was indicted for two murders and armed robbery and convicted on all charges. Defendant later filed a motion for a new trial, which the superior court denied. The Supreme Judicial Court affirmed Defendant's convictions of murder in the first degree but vacated and set aside the armed robbery conviction, holding (1) as to Defendant's murder convictions, he was not entitled to relief on his allegations of error, and there was no ground for granting relief pursuant to Mass. Gen. Laws ch. 278, 33E; and (2) the armed robbery conviction was duplicative of the felony-murder conviction for the killing of Hall and therefore must be dismissed. View "Commonwealth v. Bateman" on Justia Law