Justia Civil Rights Opinion Summaries

Defendant was convicted of murder in the first degree on a theory of felony-murder, based on the predicate felony of aggravated rape, and aggravated rape. Defendant was sentenced to concurrent terms of life in prison. The Supreme Judicial Court affirmed the conviction of murder of the first degree and ordered dismissal of the aggravated rape conviction as duplicative, holding (1) there was no error in the denial of Defendant’s motion for a required finding of not guilty; (2) the trial court correctly denied Defendant’s motion to suppress two statements Defendant made to police; (3) the trial court did not err in admitting testimony from the victim’s daughter; (4) there was no error in the admission into evidence of Defendant’s prior bad acts; (5) the prosecutor did not commit prejudicial misconduct during closing arguments; (6) the trial judge did not abuse his discretion in denying Defendant’s motion to reduce the verdicts; and (7) the conviction on the indictment alleging aggravated rape is duplicative of the conviction of felony-murder and must be dismissed. View "Commonwealth v. Mazariego" on Justia Law

Stansfield sought a harassment prevention order against Van Liew alleging four incidents of harassment. The alleged harassment concerned a local municipal election and general issues of local public concern. The District Court judge denied the request. Van Liew then filed this action against Stansfield in the district court, asserting claims for abuse of process and malicious prosecution. Stansfield filed a special motion to dismiss pursuant to Mass. Gen. Laws ch. 238, 59H. The District Court judge allowed the special motion after a hearing. Van Liew appealed to the Appellate Division of the District Court Department. The Appellate Division vacated the order of dismissal, concluding that Van Liew had presented sufficient evidence to show that Stansfield lacked any reasonable factual support for her petitioning activity. Stansfield filed an appeal in the Appeals Court from the decision and order of the Appellate Division. The Supreme Judicial Court affirmed, holding (1) Stansfield’s appeal was properly filed in the Appeals Court; and (2) with one possible exception, the speech at issue in this case did not qualify as either “fighting words” or “true threats,” and therefore, no civil harassment prevention order should have issued. View "Van Liew v. Stansfield" on Justia Law

Defendants were charged with shoplifting by concealing merchandise and unlawfully carrying a firearm. Defendants moved to suppress the firearm discovered during the inventory search of the vehicle that they used to travel to the department store. The vehicle was lawfully parked in the department store lot, and, after Defendants were arrested for shoplifting, the driver of the vehicle told the police that the registered owner of the vehicle could pick up the vehicle as an alternative to having it towed. The motion judge allowed Defendants’ motion to suppress, concluding that the seizure of the vehicle that preceded the inventory search was not reasonable. The Supreme Judicial Court affirmed, holding that it was unreasonable and, thus, unconstitutional to impound the vehicle and conduct an inventory search where the driver offered the police an alternative to impoundment that was lawful and practical under the circumstances. View "Commonwealth v. Oliveira" on Justia Law

Defendants were charged with shoplifting by concealing merchandise and unlawfully carrying a firearm. Defendants moved to suppress the firearm discovered during the inventory search of the vehicle that they used to travel to the department store. The vehicle was lawfully parked in the department store lot, and, after Defendants were arrested for shoplifting, the driver of the vehicle told the police that the registered owner of the vehicle could pick up the vehicle as an alternative to having it towed. The motion judge allowed Defendants’ motion to suppress, concluding that the seizure of the vehicle that preceded the inventory search was not reasonable. The Supreme Judicial Court affirmed, holding that it was unreasonable and, thus, unconstitutional to impound the vehicle and conduct an inventory search where the driver offered the police an alternative to impoundment that was lawful and practical under the circumstances. View "Commonwealth v. Oliveira" on Justia Law

Defendant, who is not a citizen of the United States, pleaded guilty to one count of possession of cocaine. Defendant was subsequently placed in a removal proceeding. Defendant filed a motion to vacate his guilty plea, claiming that he received ineffective assistance from his plea counsel when counsel provided erroneous advice that Defendant would not be subject to deportation. The motion was denied. The Supreme Judicial Court concluded that Defendant received ineffective assistance of plea counsel and remanded the matter for additional findings relating to the issue of prejudice. On remand, the judge allowed Defendant’s motion to vacate his guilty plea and ordered a new trial. The Supreme Judicial Court affirmed, holding (1) the judge did not abuse his discretion in allowing Defendant’s motion for a new trial; and (2) the affidavits of Defendant and his plea counsel provided a sufficient basis to conclude that, but for counsel’s errors, Defendant would not have pleaded guilty and would have decided instead on going to trial. View "Commonwealth v. Sylvain" on Justia Law

After a jury trial, Defendant was found guilty of attempted armed robbery and murder in the first degree on theories of extreme atrocity or cruelty and felony murder. Defendant was sentenced to life imprisonment on the murder charge. Defendant appealed, challenging the admission into evidence of his videotaped statement to the police and a statement he made while he was left alone during the police interrogation. Specifically, Defendant argued that although he initially waived his Miranda rights, he later invoked his right to remain silent and that the police did not scrupulously honor this invocation. Defendant failed to raise this claim below. The Supreme Judicial Court reversed Defendant’s convictions, holding that the police’s failure to honor Defendant’s right to terminate questioning created a substantial likelihood of a miscarriage of justice because the statement was likely to have affected the jury’s verdict. View "Commonwealth v. Smith" 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. Defendant subsequently filed a motion for a new trial based on alleged trial errors. The motion was denied after an evidentiary hearing. The Supreme Judicial Court affirmed the order denying Defendant’s motion for new trial as well as Defendant’s conviction and discerned no basis to exercise its authority pursuant to Mass. Gen. Laws ch. 278, 33E, holding (1) the trial court erroneously admitted certain DNA evidence, but there was no substantial likelihood of a miscarriage of justice; (2) trial counsel was not ineffective for introducing audiotapes of prior consistent statements made by the Commonwealth’s principal witness for impeachment purposes; (3) there was no substantial likelihood of a miscarriage of justice created by the admission of a cooperating codefendant’s plea agreement without prior redaction; (4) there was no error in the admission of prior bad act evidence; and (5) trial counsel did not provide ineffective assistance. View "Commonwealth v. Lally" on Justia Law

Plaintiff, a black male of African descent who had a medical degree from the University of the West Indies, was terminated from his employment with Mount Auburn Hospital while completing the first year of his residency. Plaintiff filed a ten-count complaint against the Hospital and three physicians who supervised his work, asserting employment discrimination and breach of contract, among other claims. The Appeals Court reversed as to the discrimination and breach of contract claims. The Supreme Judicial Court vacated the judgments in favor of Defendants on Plaintiff’s claims for employment discrimination and breach of contract, holding that Defendants were not entitled to summary judgment and that Plaintiff presented sufficient evidence to allow a jury to hear his claims. View "Bulwer v. Mount Auburn Hospital" 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 and of armed assault with intent to murder. The Supreme Judicial court affirmed Defendant’s convictions but vacated the trial court order denying Defendant’s first motion for a new trial, holding (1) the trial court did not err in admitting evidence of the decedent’s out-of-court statement about who had shot him; (2) the performance of Defendant’s first counsel was ineffective, and it is necessary to vacate the denial of Defendant’s first motion for a new trial and to remand the case for an evidentiary hearing to determine whether Defendant was prejudiced by his counsel’s deficient performance; and (3) any impropriety on the part of the prosecutor did not create a substantial likelihood of a miscarriage of justice. View "Commonwealth v. Celester" on Justia Law

Police officers applied for and obtained a warrant to search Defendant’s iPhone. The warrant authorized a search of Defendant’s iPhone for evidence of communications that would link him and another suspect to a shooting. The search resulted in the discovery and seizure of photographs of Defendant holding a gun. Defendant was subsequently charged with possession of a firearm without a license and related offenses. Defendant moved to suppress the photographs obtained from the search of his iPhone. The motion judge denied the motion to suppress, concluding that it was appropriate for the police to search the files on Defendant’s phone that contained his photographs. The Supreme Judicial Court affirmed, holding (1) because communications relating to and linking Defendant to the crimes under investigation would be found in photograph form on Defendant’s iPhone, a search of the photograph files was reasonable; and (2) the photographs at issue were properly seized as evidence linking Defendant to the crimes under investigation. View "Commonwealth v. Dorelas" on Justia Law