Justia Civil Rights Opinion Summaries

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

After a jury trial, Defendant was convicted of murder in the first degree on the theory of extreme atrocity or cruelty. While his appeal was pending, Defendant filed a motion for a new trial. The motion was denied. Defendant’s appeal from the denial of the motion was consolidated with his direct appeal. The Supreme Judicial Court affirmed Defendant’s conviction and the denial of his motion for a new trial, holding (1) the prosecutor at times crossed over the line of propriety in his conduct at trial, including in his cross-examination of Defendant and in his closing argument, but the errors did not create a substantial likelihood of a miscarriage of justice; and (2) there was no reason to reduce the verdict or to order a new trial. View "Commonwealth v. Cadet" on Justia Law

At issue in this case was whether settlement agreements between a public school and the parents of a public school student who requires special education are public records subject to disclosure. Plaintiff requested from Defendant school district copies of such agreements where Defendant “limited its contribution to education funding or attached conditions for it for out of district placements” for certain school years. The school district denied the request. The superior court declared that the agreements were public records and were not exempt from disclosure. The Supreme Judicial Court vacated the judgment of the superior court and remanded, holding (1) the settlement agreements regarding placement of students in out-of-district private educational institutions are not “public records” under Mass. Gen. Laws ch. 4, 7; but (2) the settlement agreements may be redacted to remove personally identifiable information, after which they become subject to disclosure under Mass. Gen. Laws ch. 66, 10, the Massachusetts public records law. View "Champa v. Weston Public Schools" on Justia Law