Justia Civil Rights Opinion Summaries

The Supreme Judicial Court reversed the decision of the trial court convicting Defendant of operating a motor vehicle while under the influence of alcohol (OUI) and negligent operation of a motor vehicle, holding that the trial court erred in denying Defendant's motion to suppress.Defendant moved to suppress the results of a blood alcohol content (BAC) analysis conducted by a crime lab after the police obtained and executed a search warrant for Defendant's blood, arguing that he did not consent to having his blood tested. The trial judge denied the motion. The Supreme Judicial Court reversed, holding that, in a prosecution under 24(1)(a), where the Commonwealth wishes to have admitted BAC evidence arising from testing or analysis of a defendant's blood done "by or at the direction of" police, police must first obtain the defendant's consent to the "chemical test or analysis" of his blood that may result from such evidence, regardless of whomever first drew the blood. View "Commonwealth v. Moreau" on Justia Law

The Supreme Judicial Court affirmed the judgment of a single justice of the court denying Plaintiff's emergency complaint for relief in the nature of mandamus, holding that the single justice neither erred nor abused his discretion in denying Plaintiff's request for mandamus relief.In her complaint, Plaintiff requested that the single justice compel the Secretary of Housing and Economic Development to award her certain benefits under the Emergency Rental Assistance Program and to help her locate a home with suitable accommodations under the Americans with Disabilities Act. The single justice denied the request without a hearing. The Supreme Judicial Court affirmed, holding that mandamus relief was not appropriate in this case. View "Linardon v. Secretary of Housing and Economic Development" on Justia Law

The Supreme Judicial Court vacated the opinion of a panel of the appeals court affirming the probation violation hearing judge's ruling that Probationer had violated the terms of his probation by committing new crimes, revoking his probation, and sentencing him to a term of incarceration, holding that Probationer's inability to question his accuser violated his right to present a defense.The hearing justice revoked Probationer's probation on the basis of hearsay statements by the complainant, his former fiancee, who alleged that Probationer had repeatedly raped her over a period of four months when they were living together. On appeal, Probationer argued that his constitutional due process rights were violated because the complainant did not appear at the hearing to testify or to be cross-examined. The Supreme Judicial Court agreed, holding that precluding Probationer from calling the accuser as a witness at the hearing violated Probationer's due process right to present a defense. View "Commonwealth v. Costa" on Justia Law

The Supreme Judicial Court affirmed the order of a judge of the superior court granting Defendant's motion to suppress evidence of a firearm discovered during what Defendant alleged was an unlawful patfrisk, holding that the motion to suppress was properly granted.The Commonwealth filed an interlocutory appeal challenging the grant of Defendant's motion to suppress, arguing that the officers' suspicion that Defendant was armed and dangerous was reasonable. The Supreme Judicial Court disagreed, holding (1) the motion judge properly found that Defendant's behavior did not create reasonable suspicion that he was armed and dangerous; and (2) Defendant's reactions to the traffic stop did not justify the subsequent patfrisk. View "Commonwealth v. Garner" on Justia Law

The Supreme Judicial Court affirmed the judgment of the single justice of the court granting in part Defendant's gatekeeper petition to appeal from the denial of his motion for a new trial and reversed the motion judge's denial of Defendant's motion, holding that the Commonwealth violated its obligation under Brady v. Maryland, 373 U.S. 83 (1963), and prejudiced Defendant.In 1986, Defendant was convicted of murder in the first degree. The Supreme Judicial Court affirmed the conviction on appeal. At issue before the Supreme Judicial Court was Defendant's second motion for a new trial, in which Defendant alleged that several pieces of evidence were not disclosed at his criminal trial. The motion judge denied the motion. The Supreme Judicial Court reversed, holding that Defendant established that the Commonwealth failed to disclose exculpatory evidence and that such nondisclosure was prejudicial. View "Commonwealth v. Pope" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions for four counts of murder in the first degree on the theory of felony-murder and the order denying his motion for a new trial and declined to grant relief under Mass. Gen. Laws ch. 278, 33E, holding that Defendant was not entitled to relief on any of his allegations of error.Specifically, the Supreme Judicial Court held (1) the judge did not abuse his discretion in denying Defendant's motion for a new trial; (2) Defendant's trial counsel did not provide ineffective assistance of counsel; (3) Defendant's argument that exculpatory evidence pointed to another suspect was unavailing; (4) the prosecutor did not commit misconduct during closing arguments; and (5) the judge did not abuse his discretion in declining to strike a juror. View "Commonwealth v. Moore" on Justia Law

The Supreme Judicial Court affirmed the judgment of a superior court judge denying the special motion to dismiss under Mass. Gen. Laws ch. 231, 59H, the anti-SLAPP statute, filed by Exxon Mobil Corporation in this civil enforcement action brought by the Attorney General, holding that the anti-SLAPP statute does not apply to civil enforcement actions by the Attorney General.The Attorney General brought this action against Exxon Mobil for various alleged violations of Mass. Gen. Laws ch. 93A based on the company's communications regarding the impact of climate change with investors and consumers. Exxon Mobil filed an anti-SLAPP motion, asserting that the action was motivated by its "petitioning" activity. The superior court judge denied the motion on the ground that at least some of the activity alleged in the complaint was not "petitioning" under the statute. The Supreme Judicial Court affirmed on an alternate ground, holding that Mass. Gen. Laws ch. 231, 59H does not apply to civil enforcement actions brought by the Attorney General. View "Commonwealth v. Exxon Mobil Corp." on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of felony-murder in the first degree and the denial of his motion for a new trial, holding that there was no error that would necessitate a new trial, and there was no reason for the Court to exercise its authority under Mass. Gen. Laws ch. 278, 33E to order a new trial or to reduce the conviction to a lesser degree of guilt.On appeal, Defendant argued, among other things, that his felony-murder conviction must be reversed because his accomplice was killed during a struggle with the intended robbery victim, and therefore, the theory of felony-murder was inapplicable. The Supreme Judicial Court affirmed, holding (1) the felony-murder rule was applicable; (2) the evidence was sufficient to support Defendant's convictions; and (3) Defendant's remaining assignments of error were without merit. View "Commonwealth v. Duke" on Justia Law

The Supreme Judicial Court held that the superior court erred in denying Defendant's motion to dismiss insofar as it concerned the charge of murder in the first degree on a joint venture theory, holding that there was insufficient evidence to support this conviction.Defendant charged with murder in the first degree on theories of deliberate premeditation and extreme atrocity or cruelty, accessory after the fact to murder, carrying a firearm without a license, and carrying a loaded firearm without a license. After four days of deliberations the jury deadlocked, and the trial judge declared a mistrial. Defendant then filed a motion to dismiss, arguing that a retrial would violate his right against double jeopardy. After the motion judge denied the motion Defendant filed a petition pursuant to Mass. Gen. Laws ch. 211, 3. The Supreme Judicial Court remanded the cause, holding that there was insufficient evidence that Defendant shared the lethal intent of the shooter required to support a conviction of murder in the first degree on a joint venture theory. View "Baxter v. Commonwealth" on Justia Law

The Supreme Judicial Court held that "tower dumps" are not per se unconstitutional and that investigators may use tower dumps so long as they comply with the warrant requirements of article 14 of the Massachusetts Declaration of Rights.The Commonwealth obtained search warrants for seven different "tower dumps," a law enforcement tool that provides investigators with the cell site location information for all devices that connected to specific cell towers during a particular time frame, corresponding to the locations of several crimes. Defendant was ultimately charged with six robberies and a homicide. Defendant moved to suppress all evidence obtained from the tower dumps as the fruit of an unconstitutional search. The superior court judge denied the motion. The Supreme Judicial Court reversed in part, holding (1) investigators may use tower dumps so long as they comply with the warrant requirements of article 14; (2) the second of the two warrants in this case was supported by probable cause and therefore did not offend the Massachusetts Declaration of Rights; but (3) the first warrant was not supported by probable cause, and any evidence obtained from it must be suppressed. View "Commonwealth v. Perry" on Justia Law