Justia Civil Rights Opinion Summaries

The Supreme Judicial Court affirmed Defendant’s conviction for murder in the first degree on theories of extreme atrocity or cruelty and deliberate premeditation, holding that there was no error in this case warranting reversal, nor was there any reason for the Court to exercise its authority under Mass. Gen. Laws ch. 278, 33E to reduce the verdict or order a new trial. Specifically, the Supreme Judicial Court held (1) the trial court did not err in denying Defendant’s motion to suppress a statement Defendant made to police; (2) the evidentiary rulings challenged by Defendant were unavailing; (3) there was no prejudicial error in the jury instructions; (4) the trial judge did not abuse his discretion in failing to dismiss several jurors for cause; (5) any potential prejudice to Defendant from the prosecutor’s closing argument was mitigated by a comprehensive limiting instruction; and (6) Defendant’s mandatory sentence of life in prison without the possibility of parole is constitutional. View "Commonwealth v. Colton" on Justia Law

Following a series of disciplinary reprimands and suspensions for misconduct, Plaintiff was removed from her positions as an assistant clerk-magistrate of the Salem Division of the District Court Department. Plaintiff brought this action challenging her removal, arguing that the decision to remove her exceeded the clerk-magistrate’s statutory authority, was arbitrary or capricious, and violated her due process rights. The superior court upheld the removal decision. The Supreme Judicial Court affirmed, holding that it was appropriate for the clerk-magistrate to factor in the whole of Plaintiff’s disciplinary record in terminating her, and therefore, the clerk-magistrate’s decision was not arbitrary or capricious, due process was satisfied, and Plaintiff demonstrated no deviation from the governing statute or rules. View "Perullo v. Advisory Committee on Personnel Standards" on Justia Law

Defendant was charged with offenses arising from alleged domestic violence. The Commonwealth and Defendant filed motions in limine regarding the admissibility of a record of a 911 call placed by the son of Defendant and the alleged victim. Defendant argued that the boy’s statements - including, “my dad just choked my mom” - were not excited utterances and that their admission would violate his right of confrontation right. The judge concluded that the statements were not excited utterances because the boy’s voice on the recording sounded “calm.” A single justice vacated the judge’s order excluding the recording. The Supreme Judicial Court affirmed, holding that the question is not whether the declarant shows “excitement,” but, rather, whether the declarant was acting spontaneously under the influence of the incident at the time the statements were made, and not reflexively. Remanded. View "Commonwealth v. Baldwin" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on the theories of deliberate premeditation and extreme atrocity or cruelty, and armed home invasion. After filing a notice of appeal, Defendant filed a motion for a new trial arguing that his trial counsel was constitutionally ineffective for failing to investigate and present a defense of lack of criminal responsibility. Defendant also filed a second motion for a new trial. The trial court denied Defendant’s two motions for a new trial. The Supreme Judicial Court affirmed Defendant’s convictions and the orders denying the motions for a new trial and declined to reduce the verdict or grant a new trial, holding (1) the trial judge did not err in denying Defendant’s first motion for a new trial, as trial counsel’s decision to forgo further investigation of a lack of criminal responsibility defense based on mental illness was not error; and (2) Defendant’s remaining claims of error were either procedurally waived or without merit. View "Commonwealth v. Holland" on Justia Law

For the first decade of his employment with the Boston police department, Plaintiff was a patrol officer performing the full range of patrol officer duties. The department later placed Plaintiff on administrative duty due to his loss of cognitive function and memory and his “neuropsychological problem of speed and accuracy.” The Boston Patrolmen’s Association subsequently filed a grievance on Plaintiff’s behalf demanding that he be permitted to resume the duties of a patrol officer. An arbitrator found that the Department did not act unreasonably in placing Plaintiff on administrative duty. Plaintiff filed a discrimination lawsuit against the city. The motion judge allowed the city’s motion for summary judgment. The Supreme Judicial Court reversed, holding that summary judgment was not appropriate because there were facts in dispute as to whether Plaintiff was a qualified handicapped person capable of performing the full duties of a patrol officer without posing an unacceptably significant risk of serious injury to himself or others. View "Gannon v. City of Boston" on Justia Law

In 2005, a few weeks after Child was born, Child's Grandmother was appointed as Child’s permanent guardian and has remained so ever since. Mother filed this removal proceeding challenging the guardianship arrangement. In 2016, Child, through counsel, filed a motion to appoint counsel for her guardian. The motion was denied. The Supreme Judicial Court remanded the case to the probate and family court for further proceedings, holding (1) a guardian who has a de facto parent relationship with her ward does not have a liberty interest in that relationship such that she has a procedural due process right to counsel; but (2) a probate and family court judge may, in the exercise of his sound discretion, grant a motion requesting counsel for a guardian in a removal proceeding where the judge concludes that doing so would materially assist in determining the best interests of the child. View "In re Guardianship of K.N." on Justia Law

Defendant was charged with operating while under the influence of intoxicating liquor, second offense, and a marked lanes violation. The charges stemmed from a single vehicle accident in which the vehicle Defendant was driving rolled over. Defendant filed a motion in limine to exclude from her medical records evidence of a blood alcohol test taken after she was transported to the hospital based on her right to confrontation under the Sixth Amendment. A district court judge allowed the motion. A single justice vacated the trial judge’s order allowing the motion in limine and ordered that the blood alcohol test evidence was admissible. The Supreme Judicial Court affirmed, holding that it was “eminently logical” that the blood alcohol test administered to Defendant was performed as a routine medical practice in the course of Defendant’s treatment following the accident. View "Commonwealth v. Ackerman" on Justia Law

Defendant was convicted of murder in the first degree on the theories of deliberate premeditation and extreme atrocity or cruelty. The Supreme Judicial Court affirmed Defendant’s convictions and the trial court’s denial of his motion for a new trial and declined to grant extraordinary relief pursuant to Mass. Gen. Laws ch. 278, 33E, holding (1) Defendant received constitutionally effective assistance of counsel at trial; (2) Defendant was given a meaningful opportunity to present a complete defense; and (3) the trial judge did not deprive Defendant of his right to a fair trial by denying Defendant’s request to give a voluntary manslaughter instruction. View "Commonwealth v. Gulla" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on theories of deliberate premeditation and extreme atrocity or cruelty, arson of a dwelling house, and violating an abuse prevention order. The Supreme Judicial Court affirmed the convictions and declined to reduce the degree of guilt or to order a new trial, holding (1) the evidence was sufficient to support Defendant’s convictions of murder in the first degree and arson; (2) the testimony of two expert witnesses did not violate Defendant’s right to confrontation under the Sixth Amendment; (3) Defendant’s custodial statements to police were obtained with a valid Miranda waiver and were voluntary; and (4) the motion judge did not abuse his discretion in denying Defendant’s motion for a new trial without an evidentiary hearing. View "Commonwealth v. Sanchez" on Justia Law

Police officers recovered a loaded firearm from a motor vehicle after impounding and conducting an inventory search of the vehicle. Defendant was subsequently charged with carrying a firearm without a license and possession of a firearm or ammunition without a firearm identification card. Defendant filed a motion to suppress, arguing that the officers’ decision to impound and inventory the motor vehicle was not reasonable. A district court judge allowed the motion to suppress, concluding that impoundment was improper based on its findings that the vehicle was not in danger of damage or theft. The Supreme Judicial Court affirmed the order allowing the motion to suppress, holding that it was not reasonable for the police to impound the vehicle for the purpose of protecting it from theft or vandalism, and impoundment was not warranted to protect the public. View "Commonwealth v. Crowley-Chester" on Justia Law