Justia Civil Rights Opinion Summaries

Defendant was on parole when his parole officer and others searched his apartment without a warrant and seized cocaine from his bedroom door. Defendant was indicted for possession of cocaine with intent to distribute. Defendant filed a motion to suppress the evidence seized from his home, arguing that the search was unconstitutional under both the United States and Massachusetts Constitutions. The motion judge allowed Defendant’s motion to suppress, holding that the search did not violate the Fourth Amendment but did violate article 14 of the Massachusetts Declaration of Rights. Specifically, the judge concluded that article 14 offers the same protections for parolees as it does for probations and that searches of a parolee’s residence must be supported by both reasonable suspicion and either a search warrant or a traditional exception to the search warrant. The Supreme Judicial Court vacated the allowance of Defendant’s motion to suppress, holding (1) article 14 does not offer as much protection to parolees as it affords to probationers, and therefore, reasonable suspicion is sufficient to justify a warrantless search of the parolee’s home; and (2) the officer in this case had reasonable suspicion that a search of Defendant’s home would produce evidence of a parole violation. View "Commonwealth v. Moore" on Justia Law

Defendant was stopped by a state police trooper, who was prompted by the receipt of an anonymous 911 call concerning an apparent drunk driver. After a bench trial, Defendant was convicted of operating a motor vehicle while under the influence of alcohol. Defendant appealed, arguing that the trial court erred in denying his motion to suppress the evidence obtained during the warrantless stop of his vehicle because the stop was neither supported by reasonable suspicion nor made pursuant to an ongoing emergency. The appeals court affirmed the denial of Defendant’s motion to suppress, concluding that the information bore sufficient indicia of reliability, and therefore, the trooper could rely on the information in establishing reasonable suspicion to conduct an investigatory stop. The Supreme Judicial Court affirmed, holding that the information gathered from the anonymous call, corroborated by other information, was sufficiently reliable to warrant a finding that the trooper had reasonable suspicion to stop Defendant’s vehicle. View "Commonwealth v. Depiero" on Justia Law

After a jury trial, Defendant was found guilty of murder in the first degree on the theory of deliberate premeditation. Defendant appealed, asserting, among other claims, that he was entitled to a new trial because he was denied his constitutional right to the effective assistance of counsel for two reasons. The Supreme Judicial Court affirmed Defendant’s convictions and declined to exercise its authority to order a new trial or to reduce the verdict of murder in the first degree, holding (1) counsel’s alleged errors were not likely to have influenced the jury’s conclusion; and (2) Defendant’s claims that various errors were made by the prosecutor and judge were without merit. View "Commonwealth v. Gonzalez" on Justia Law

After learning that two of the guests from a party at Defendant’s house were ill from ingesting tequila and that Defendant might also be ill, the police entered Defendant’s home to perform a well-being check under the “emergency aid” exception to the constitutional warrant requirement. While there, the police seized two tequila bottles, one of which was found to contain a so-called “date rape” drug. Defendant filed a motion to suppress, which the trial court denied. After a jury trial, Defendant was convicted of rape, drugging for sexual intercourse, and drugging to confine. The Supreme Judicial Court vacated the judgments of conviction, holding (1) the police had objectively reasonable grounds to believe that Defendant may be in need of immediate medical assistance, and therefore, the warrantless entry into Defendant’s home was justified; but (2) the seizure of the evidence was unreasonable because (i) it occurred after Defendant was transported to the hospital and while the police remained in his home without his consent, and (ii) the police seized the evidence for investigative purposes without verifying any demonstrable relationship to the emergency justifying their entry into Defendant’s home. Remanded for a new trial. View "Commonwealth v. Kaeppeler" on Justia Law

After a jury trial, Defendant was convicted of two counts of armed robbery, two counts of murder in the first degree, and one count each of home invasion, unlawful possession of ammunition, and possessing a firearm without a license. The Supreme Judicial Court affirmed the convictions and declined to exercise its authority pursuant to Mass. Gen. Laws ch. 278, 33E, holding (1) the trial court did not err in denying Defendant’s motion to suppress the firearm used in the armed robbery and murders; and (2) Defendant’s right to due process was not violated by the joinder of his trial with his codefendants and in the joinder of the armed robbery charges and charges relating to the home invasion. View "Commonwealth v. Hernandez" on Justia Law

Defendant was charged with malicious destruction of property over $250. The charge was based on the allegation that Defendant caused a security gate at his property to strike and damage the complaining witness’s (CW) vehicle. During discovery, Defendant filed a request for mandatory discovery of the CW’s criminal record. The probation department produced the unsealed entries in the CW’s criminal record but withheld the entries sealed pursuant to Mass. Gen. Laws ch. 276, 100A. Thereafter, Defendant filed a motion to compel production of the sealed criminal record. The judge denied the motion. Defendant subsequently filed this petition for review pursuant to Mass. Gen. Laws ch. 211, 3, claiming that mandatory disclosure required by Mass. Gen. Laws ch. 218, 26A and Mass. R. Crim. P. 14(a)(1)D) is not subject to an exception for sealed criminal records and that disclosure was necessary to effect his constitutional right to confrontation of the CW. The Supreme Judicial Court denied relief, holding (1) the mandatory discovery provisions of Mass. Gen. Laws ch. 218, 26A and Rule 14(a)(1)(D) do not apply to criminal records sealed pursuant to Mass. Gen. Laws ch. 276, 100A; and (2) Defendant failed to establish a constitutional right to disclosure for confrontation purposes. View "Wing v. Comm’r of Probation" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on theories of deliberate premeditation, extreme atrocity or cruelty, and felony-murder. The Supreme Judicial Court affirmed Defendant’s convictions and declined to grant relief pursuant to Mass. Gen. Laws ch. 278, 33E, holding (1) the trial judge did not err in admitting medical records and related testimony and by instructing the jury on consciousness of guilt; (2) the trial judge did not err in admitting expert testimony concerning the statistical significance of DNA evidence; (3) the trial judge did not err by admitting the victim’s T-shirt into evidence, despite a purported discovery violation by the Commonwealth; (4) the prosecutor did not commit misconduct during her opening statement or her closing argument; and (5) the trial judge properly denied Defendant’s motion for required findings of not guilty. View "Commonwealth v. Cole" on Justia Law

After a trial, Defendant was convicted of murder in the first degree. Defendant appealed. Defendant also filed a motion for a new trial, arguing that she was deprived of the effective assistance of trial counsel. Defendant’s appeal was stayed pending resolution of her motion for a new trial. On the Commonwealth’s motions, the trial judge ordered that trial counsel be summonsed to testify at the hearing on Defendant’s motion and that Defendant provide the Commonwealth with certain discovery. Defendant subsequently filed a petition pursuant to Mass. Gen. Laws ch. 211, 3 seeking relief from these orders. A single justice of the Supreme Judicial Court denied extraordinary relief. The Supreme Judicial Court affirmed, holding that Defendant had an adequate alternative remedy by way of appeal from any adverse ruling on the motion for a new trial. View "Field v. Commonwealth" on Justia Law

After a jury trial, Defendant was found guilty of murder in the first degree. The Supreme Judicial Court affirmed the convictions and the trial court’s denial of Defendant’s motion for a new trial and declined to reduce the degree of guilt pursuant to Mass. Gen. Laws ch. 278, 33E, holding (1) there was sufficient evidence to sustain Defendant’s conviction; (2) Defendant suffered no prejudice as a result of the Commonwealth’s failure to disclose certain evidence; (3) there was no error due to the Commonwealth’s exclusion of third-party culprit evidence; (4) the judge judge did not abuse her discretion in denying Defendant’s motion to exclude hearsay statements by the victim’s girl friend; (5) the prosecutor did not engage in impermissible misconduct; (6) defense counsel’s performance was not constitutionally deficient; and (7) Defendant failed to establish that a new trial was required because the prosecutor had represented him on several previous occasions. View "Commonwealth v. Watkins" on Justia Law

In 1995, Randall Trapp and four other inmates, who were adherents of Native American religious practices, filed a complaint asserting that the Department of Correction (DOC) had violated their rights to exercise their religion. In 2003, the parties entered into a settlement agreement requiring the DOC to construct a purification lodge at the Souza-Baranowski Correctional Center (SBCC). Within six months of building the SBCC lodge, the DOC halted all ceremonies, citing health concerns that resulted from smoke filtering into the main building from wood fires at the lodge. In 2010, Trapp and Robert Ferreira filed an amended complaint against the Commissioner of Correction and two DOC employees at the Massachusetts Correctional Institution at Norfolk, alleging that the lodge’s closure violated the Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA), article 2 of the Massachusetts Declaration of Rights, and the 2003 settlement agreement. A superior court judge entered a declaratory judgment in favor of Plaintiffs on all three claims. The Supreme Judicial Court affirmed, holding that the closure of the SBCC lodge violated RLUIPA and the settlement agreement. View "Trapp v. Roden" on Justia Law