Justia Civil Rights Opinion Summaries

The Supreme Judicial Court affirmed Defendant’s conviction of murder in the first degree, as a joint venturer, holding that none of the arguments Defendant raised on appeal warranted reversal of his convictions.During trial, the Commonwealth proceeded on a theory of felony-murder, with armed home invasion and attempted armed robbery as the predicate felonies. The Supreme Judicial Court affirmed Defendant’s convictions and declined to exercise its authority to grant relief under Mass. Gen. Laws ch. 278, 33E, holding (1) the evidence was sufficient to support the convictions; (2) the trial judge did not abuse her discretion in allowing cell site location information evidence; (3) the judge did not err when she did not instruct the jury that they were allowed to reach factually inconsistent verdicts; and (4) this Court declines to abolish the common-law doctrine of felony-murder. View "Commonwealth v. Bin" on Justia Law

The Supreme Judicial Court reversed the trial court’s order suppressing statements that Defendant made during custodial interrogations and suppressing the results of the forensic testing of Defendant’s bloodstained clothing, holding (1) a remand was necessary to determine whether the suppression of Defendant’s statements was proper; and (2) the police lawfully seized Defendant’s clothing incident to arrest and did not need a separate warrant to test the clothing for the presence of human blood.Defendant was charged with murder in the first degree in connection with the beating death of a woman who had obtained a restraining order against him. The motion judge determined that Defendant was too intoxicated during custodial interviews to make a knowing, intelligent, and voluntary Miranda waiver. The Supreme Judicial Court disagreed, holding (1) a remand was necessary for the trial judge to make findings and credibility determinations regarding all pertinent evidence in light of this Court’s de novo assessment of the recording of Defendant’s second custodial interview; and (2) the order suppressing the results of the forensic testing of Defendant’s clothing must be reversed. View "Commonwealth v. Tremblay" on Justia Law

The Supreme Judicial Court vacated Defendant’s conviction of murder in the first degree on the theory of deliberate premeditation, holding that the judge erred by declining to require an explanation for the prosecutor’s preemptory challenge to a female African-American member of the venire and erred in declining to give Defendant’s requested jury instructions on self-defense and voluntary manslaughter.The shooting that led to the fatality in this case was precipitated by a drug turf war. At the close of the evidence Defendant requested that the jury be instructed on self-defense and voluntary manslaughter, but the request was denied. The Supreme Judicial Court reversed, holding (1) the trial judge abused her discretion by declining to require the prosecutor to provide and adequate and genuine race-neutral reason for Defendant’s peremptory challenge to the juror at issue; and (2) considered in the light most favorable to Defendant, the evidence warranted instructions on self-defense and voluntary manslaughter based on the theory of excessive use of force in self-defense. View "Commonwealth v. Ortega" on Justia Law

In this criminal matter, the Supreme Judicial Court held that maintaining pending charges against an incompetent defendant where the defendant will never regain competency and where maintaining the charges does not serve the compelling State interest of protecting the public violates the defendant’s substantive due process rights.In 1994, Defendant was charged with murder in the first degree but was deemed incompetent to stand trial. After unsuccessfully filing a series of motions to dismiss and for reconsideration, in 2016, Defendant sought relief pursuant to Mass. Gen. Stat. ch. 211, 3 arguing that he was permanently incompetent to stand trial and dismissal of the charges was required. At issue was Mass. Gen. Laws ch. 123, 16(f), which requires mandatory dismissal of charges at the time when the defendant would have been eligible for parole if he had been convicted and sentenced to the maximum statutory sentence. Defendant argued that the statute should be interpreted to apply to all crimes, regardless of parole eligibility. The Supreme Judicial Court agreed, holding that the statute satisfies due process requirements only insofar as it is understood to allow the dismissal of charges, in the interest of justice, where the defendant will never regain competency and does not pose a risk to public safety. View "Sharris v. Commonwealth" on Justia Law

The Supreme Judicial Court reversed the superior court judge’s denial of Defendant’s motion for resentencing, holding that Defendant, a juvenile convicted of armed home invasion, was sentenced to a mandatory minimum term exceeding that applicable to a juvenile convicted of murder without a hearing under Miller v. Alabama, 467 U.S. 460, 477-478 (2012), in violation of the requirements announced in Commonwealth v. Perez, 477 Mass. 677 (2017) (Perez I), and refined in Commonwealth v. Perez, 480 Mass. __ (2018) (Perez II), also decided today.Defendant was adjudicated a youthful offender on indictments charging armed home invasion and various related offenses and was sentenced to a mandatory minimum prison term of twenty years to twenty years and one day on the armed him invasion charge. Defendant later filed a motion for relief from unlawful restraint, which the juvenile court judge denied. The Supreme Judicial Court vacated the order denying Defendant’s motion and remanded to the juvenile court for resentencing, holding that Defendant’s sentence violated the proportionality requirement inherent in article 26 of the Massachusetts Declaration of Rights. View "Commonwealth v. Lutskov" on Justia Law

The Supreme Judicial Court vacated the trial judge’s grant of the motions to dismiss filed by the two defendants in these companion cases and remanded the cases for trial, holding that Defendants were not entitled to dismissals because Defendants’ right to a speedy trial under Mass. R. Crim. P. 36 had not been violated and because the judge abused his discretion in dismissing the indictments for failure to prosecute.Defendants moved to dismiss on the grounds that one year had elapsed since their arraignments. The trial judge allowed the motions to dismiss with prejudice. The Supreme Judicial Court vacated the dismissals, holding (1) because an essential witness resisted appearing at trial, the period that the trial was continued for this reason should be excluded under Rule 36(b)(2)(B) or (F), placing the Commonwealth within the time limits of the rule; and (2) the Commonwealth’s lack of diligence in producing the witness did not rise to the level that would warrant dismissal. The Court further held that time can be excluded under Rule 36 based on a defendant’s acquiescence only where the defendant has agreed to or failed to object to a continuance or other delay, and the scheduling of an event alone does not constitute delay. Where the defendant has acquiesced, a delay can be excluded under Rule 36 even where it does not affect the presumptive trial date. View "Commonwealth v. Graham" on Justia Law

In this appeal from the denial of a motion for reconsideration of the denial of Defendant’s motion to dismiss for lack of a speedy trial, the Supreme Judicial Court held that Defendant’s statutory and constitutional rights to a speedy trial were not violated.The Supreme Judicial Court affirmed Defendant’s convictions, holding (1) the discovery that Defendant characterized as “mandatory” and argued was untimely provided to him was not mandatory discovery; (2) even if it did constitute mandatory discovery, a defendant who does not want the speedy trial clock to be tolled where a scheduled event is continued because of the Commonwealth’s delay in providing mandatory discovery must, under Mass. R. Crim. P. 14(a)(1)(C), move to compel the production of that discovery or move for sanctions, which Defendant failed to do; (3) a criminal defendant who moves to dismiss for lack of a speedy trial on the basis that his right to a speedy trial under Rule 36 and the United States and Massachusetts Constitutions was violated, is entitled to review of such constitutional claims even where his Rule 36 claim is denied. View "Commonwealth v. Dirico" on Justia Law

The Supreme Judicial Court affirmed the superior court judge’s grant of summary judgment in favor of the director of the Office of Campaign and Political Finance (OCPF) on Plaintiffs’ claim that Massachusetts’s ban on corporate contributions, Mass. Gen. Laws ch. 55, 8, imposes an unconstitutional restraint on their rights to free speech and association and denies them their right to equal protection under the law, holding that the challenged statute is constitutional.Plaintiffs, business corporations, brought this action challenging the law limiting political spending of corporations. The superior court granted summary judgment for OCPF. The Supreme Judicial Court affirmed, holding (1) section 8 is constitutional under the First Amendment and articles 16 and 19 of the Massachusetts Declaration of Rights; and (2) section 8 does not violate the equal protection clause of the Fourteenth Amendment or Plaintiffs’ entitlement to equal protection under article 1 of the Massachusetts Declaration of Rights. View "1A Auto, Inc. v. Director of Office of Campaign & Political Finance" on Justia Law

The Supreme Judicial Court vacated Defendant’s convictions of murder in the first degree, armed robbery, and carrying a firearm without a license, holding that Defendant’s right to a fair trial as provided by Batson v. Kentucky, 476 U.S. 79 (1986) and Commonwealth v. Soares, 444 U.S. 881 (1979), was violated during the trial proceedings.On appeal, Defendant argued, among other things, that the Commonwealth improperly excluded black men from the jury. The Supreme Judicial Court agreed and remanded the case for a new trial, holding that the trial judge abused his discretion in finding no pattern after Defendant’s second objection to the Commonwealth’s use of peremptory challenges on black men. View "Commonwealth v. Robertson" on Justia Law

The Supreme Judicial Court affirmed Defendant’s conviction of possession of cocaine with intent to distribute but reversed Defendant’s conviction of criminal trespass, holding that there was insufficient evidence to support the conviction for criminal trespassing.Defendant was arrested for selling cocaine in the parking lot of a grocery store. On appeal from his convictions, Defendant challenged his convictions and the denial of his motion to suppress evidence related to his cell phone that was seized during a search incident to his arrest. The Supreme Judicial Court reversed in part, holding (1) a law enforcement officer’s testimony about the content of one of Defendant’s text massages did not constitute impermissible hearsay and was properly admitted; but (2) there was insufficient evidence to support Defendant’s conviction of criminal trespass. View "Commonwealth v. Alvarez" on Justia Law