Justia Civil Rights Opinion Summaries

Defendant was indicted for multiple firearms offenses, among other offenses. Defendant moved to suppress evidence seized during the search of a motor vehicle he had been driving. A superior court judge allowed the motion, concluding that, at the time a police officer stopped and seized the vehicle, the officer lacked a reasonable, articulable suspicion that criminal activity was afoot. The Supreme Judicial Court reversed the motion judge’s order allowing the motion to suppress, holding (1) the investigatory stop was predicated on reasonable suspicion of criminal activity; and (2) the officer’s actions were “reasonably related in scope to the circumstances which justified the interference in the first place.” View "Commonwealth v. Edwards" on Justia Law

After a jury-waived trial, Defendant was convicted of various firearm charges. On appeal, Defendant challenged the denial of his motion to suppress the firearm, asserting that police officers lacked reasonable suspicion to stop him to investigate a report of shots fired at a vehicle. The Appeals Court affirmed. The Supreme Judicial court vacated the conviction and remanded for a new trial, holding that the motion judge erred in denying the motion to suppress because, assessing the totality of the circumstances leading to the stop of Defendant, the facts known to the police at the time of the seizure were not sufficient to establish reasonable suspicion that Defendant was connected to the alleged shooting at the vehicle. View "Commonwealth v. Meneus" on Justia Law

Defendant was charged with murder in the first degree. Defendant filed a motion to suppress statements he made at two police stations, arguing that he did not knowingly and intelligently waive his Miranda rights and that the statements were not made voluntarily. Defendant then moved to impound a video recording and transcript of a police interview with Defendant that was the subject of the motion to suppress and that was subsequently suppressed. A superior court judge orally denied the motion to impound. A single justice of the Appeals Court denied Defendant’s request for interlocutory relief. A single justice of the Supreme Judicial Court vacated the denial of the motion to impound, concluding that the single justice committed an error of law and abused his discretion in affirming the judge’s denial of the motion to impound. The Supreme Judicial Court affirmed the motion judge's denial of the motion to impound, holding (1) the motion judge applied the correct legal standard in deciding Defendant’s motion to impound; and (2) the motion judge did not abuse his discretion in denying the motion to impound. View "Commonwealth v. Chism" on Justia Law

Defendant was stopped for failing to stop at a stop sign. The officer concluded that Defendant was using the vehicle without authority and decided to impound the vehicle. During an inventory search in preparation for impoundment, the officer seized a handgun and box of ammunition from the vehicle. Defendant was charged with unlawful possession of a firearm, unlawful possession of a loaded firearm, unlawful possession of ammunition without a firearm identification card, and unauthorized use of a motor vehicle. Defendant filed a motion to suppress the handgun, the ammunition, and statements he made to police. The municipal court allowed the motion to suppress. The Supreme Judicial Court affirmed the order allowing the motion to suppress, holding (1) the police did not have probable cause to believe that Defendant was operating the vehicle he was driving in violation of Mass. Gen. Laws ch. 90, 24(2)(a), and therefore, the impoundment of the vehicle was not proper; and (2) therefore, the inventory search was not lawful, and the handgun and ammunition were properly suppressed. View "Commonwealth v. Campbell" on Justia Law

Defendant was charged with murder in the first degree. A superior court judge allowed Defendant’s motion to suppress evidence recovered from his cellular telephone, concluding that the seizure of the telephone was not supported by probable cause. The Supreme Judicial Court affirmed, holding (1) probable cause to search or seize a person’s cellular telephone may not be based solely on an officer’s opinion or belief that the device is likely to contain evidence of the crime under investigation; (2) because the officers in this case lacked any information establishing the existence of relevant evidence likely to be found on Defendant’s telephone, the seizure was not supported by probable cause; and (3) the Commonwealth did not meet its burden of demonstrating that the sixty-eight-day-delay between the seizure and the application for a search warrant was reasonable. View "Commonwealth v. White" on Justia Law

After a jury-waived trial, Defendant was convicted of unlawful possession of a firearm. Defendant appealed the denial of his motion to suppress a firearm and statements he made after his arrest, arguing that the police lacked reasonable suspicion to make an investigatory stop of him in connection with a breaking and entering that had occurred in a nearby home approximately thirty minutes earlier. The Appeals Court affirmed. The Supreme Judicial Court vacated the conviction, holding that the trial court erred in denying Defendant’s motion to suppress because the police lacked reasonable suspicion for the investigatory stop. Remanded. View "Commonwealth v. Warren" on Justia Law

After a jury trial, Defendant was convicted of operating a motor vehicle while under the influence of intoxicating liquor. The Supreme Judicial Court affirmed the conviction, holding (1) the trial court did not err in admitting evidence of Defendant’s failure to properly perform a breathalyzer test after giving consent, as the evidence was not inadmissible as refusal evidence; (2) the admission of the police-appointed interpreter’s English language version of Defendant’s statements did not violate the rule against hearsay, as the interpreter acted as Defendant’s agent under the circumstances of this case; (3) Defendant’s unpreserved confrontation claim was unavailing; (4) the evidence was sufficient to establish Defendant’s impairment; and (5) there was no prejudicial error in the jury instructions. View "Commonwealth v. Adonsoto" on Justia Law

Plaintiff filed suit against against her employers (Defendants), alleging that she had been subject to a sexually hostile or offensive work environment. The jury rendered a verdict in favor of Plaintiff, finding that Defendants were liable for $40,000 in compensatory damages and $500,000 in punitive damages. The superior court judge granted Defendant’s motion for judgment notwithstanding the verdict in part, allowing the motion as to the award of punitive damages but denying it with respect to the award of compensatory damages. Both parties appealed. The Supreme Judicial Court affirmed the award of compensatory damages, reversed the judge’s order granting judgment notwithstanding the verdict as to the punitive damages award, and reinstated the jury’s verdict, holding that, based on the evidence, the jury could have found that Defendants failed to take adequate remedial measures after being put on notice of a sexually hostile or offensive work environment and that the failure was egregious or outrageous. Remanded for calculation of Plaintiff’s attorney’s fees and consideration of Defendant’s motion for remittitur as to the punitive damages award. View "Gyulakian v. Lexus of Watertown, Inc." on Justia Law

Defendant was arrested for operating while under the influence of intoxicating liquor. Defendant was not given an opportunity to consult with counsel before being required to decide whether to submit to a breathalyzer test. Defendant moved to suppress the results of the breathalyzer test, arguing that she had a right to counsel before deciding whether to submit to the breathalyzer test. After an evidentiary hearing, the district court reported a question of law asking whether the 2003 amendment to Mass. Gen. Laws ch. 90, 24, the statute establishing the offense of driving while under the influence of intoxicating liquor, now makes the decision by a defendant whether or not to take a breath test is a critical stage of the criminal proceedings requiring that the defendant be advised of his or her right to counsel prior to making that decision. The Supreme Judicial Court answered the reported question in the negative, holding that there is no right to counsel under the Sixth Amendment to the United States Constitution or article 12 of the Massachusetts Declaration of Rights before a defendant decides whether to submit to a breathalyzer test. View "Commonwealth v. Neary-French" on Justia Law

In a probation surrender proceeding based on the use of marijuana, purportedly for medical purposes, the judge found Defendant in violation of probation for the use of marijuana, terminated his probation, and imposed a prison sentence. Defendant, who was a qualifying patient under the medical marijuana law (act), appealed, arguing (1) his sentence violated his right to the medical use of marijuana without adverse legal consequences, and (2) counsel provided ineffective assistance by failing to assert the immunity provision of the act. The Supreme Judicial Court affirmed, holding (1) under the circumstances of this case, the judge did not err in finding Defendant in violation of his probation; and (2) there was no prejudice in counsel’s stipulating to the violation without raising the issue as a defense to the violation. View "Commonwealth v. Vargas" on Justia Law