Justia Civil Rights Opinion Summaries
Articles Posted in Massachusetts Supreme Judicial Court
In re Guardianship of K.N.
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
Commonwealth v. Ackerman
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
Commonwealth v. Gulla
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
Commonwealth v. Sanchez
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
Commonwealth v. Crowley-Chester
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
Commonwealth v. Tuschall
Police made two warrantless entries into Defendant’s apartment after receiving reports that it smelled like drugs. Based on observations of drug activity, the policy obtained a warrant. Thereafter, Defendant was arrested and charged with drug offenses. The trial judge granted Defendant’s motions to suppress (1) the evidence seized during the execution of the search warrant, concluding that no emergency justified the warrantless entries, without which the Commonwealth could not establish he probable cause necessary for the subsequent warrant, and (2) statements Defendant made to police following his arrest, concluding that the statements were the fruit of Defendant’s unlawful arrest. The Supreme Judicial Court affirmed, holding (1) the warrantless entries were unlawful; and (2) the Commonwealth did not meet its burden of showing that Defendant’s statements were sufficiently attenuated from the Commonwealth’s unlawful conduct. View "Commonwealth v. Tuschall" on Justia Law
Commonwealth v. Long
After a jury trial, Defendant was found guilty of murder in the first degree on a theory of deliberate premeditation. Defendant appealed from his convictions and from the trial court’s denial of his motion for a new trial, arguing, inter alia, that the motion judge erred in denying his pretrial motion to suppress the testimony of a key prosecution witness because the Commonwealth had obtained his testimony as a result of an illegal wiretap that was previously ordered suppressed. The Supreme Judicial Court affirmed and declined to exercise its authority under Mass. Gen. Laws ch. 278, 33E, holding (1) the motion judge did not err in determining that the witness’s testimony was sufficiently attenuated from the suppressed wiretap evidence to dissipate the taint of illegality; and (2) trial counsel provided constitutionally effective assistance. View "Commonwealth v. Long" on Justia Law
Commonwealth v. Mendez
Defendants, Charles Mendez and Tacuma Massie, were convicted of murder in the first degree, armed robbery, and other offenses. Both defendants were charged on a theory of felony murder. Each defendant filed a timely notice of appeal. The Supreme Judicial Court affirmed Defendants’ convictions and declined to exercise its extraordinary power under Mass. Gen. Laws ch. 278, 33E, holding (1) the trial court did not err in denying Defendants’ motions to suppress evidence seized as a result of a warrantless stop that took place soon after the shooting; (2) the motion judge did not err in deciding to join for trial certain charges; (3) two aspects of the prosecutor’s closing argument challenged by Defendants were not error; (4) there was sufficient evidence to convict Massie of the armed robbery and felony murder; and (5) Defendants’ Moffett claims were unavailing. View "Commonwealth v. Mendez" on Justia Law
Commonwealth v. Martinez
After a jury trial, Defendant was convicted of possessing child pornography. Defendant appealed, arguing that the district court erred in denying his motion to suppress computer evidence obtained pursuant to a search warrant issued for the the place searched because the police needed more information to link Defendant to the place searched and the items seized. The Supreme Judicial Court affirmed, holding that there was a substantial basis from which to conclude that the evidence of downloading and sharing child pornography via the Internet was probably present at the place to be searched. View "Commonwealth v. Martinez" on Justia Law
Commonwealth v. Pinto
After a jury trial, Appellant was convicted of two counts of unlawful possession of a loaded firearm and one count of possession of a firearm without a license. Appellant appealed, arguing that the Commonwealth failed to demonstrate that the police had reasonable suspicion to conduct an investigatory stop of his vehicle, and therefore, the trial court erred in denying his motion to suppress. The Court of Appeals agreed with Appellant and reversed the judgments of conviction, the verdicts, and the motion to suppress, holding that the police did not have reasonable suspicion to conduct the investigatory stop. View "Commonwealth v. Pinto" on Justia Law