Justia Constitutional Law Opinion Summaries

Articles Posted in Massachusetts Supreme Court
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After a jury trial, Defendant was convicted of murder in the first degree on the theory of extreme atrocity or cruelty. Defendant appealed, arguing that the trial court erred in denying his motion to suppress statements he made to police and his motion for a new trial. The Supreme Court affirmed, holding (1) the motion judge did not err in denying Defendant's motion to suppress and concluding that the Commonwealth satisfied its burden of proving beyond a reasonable doubt that Defendant made a knowing, willing, and intelligent waiver of his Miranda rights and that his statements were otherwise voluntarily made; and (2) the motion judge did not err in denying Defendant's motion for a new trial on the ground that his trial counsel provided ineffective assistance by failing to file a pretrial motion to suppress a witness's identification of Defendant, as Defendant failed to demonstrate a likelihood that a motion to suppress this evidence would have been successful. View "Commonwealth v. Jules" on Justia Law

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Defendant was convicted of murder in the first degree, armed assault with intent to murder, and two counts of illegal possession of a firearm. The Supreme Court affirmed the convictions, holding (1) the trial judge did not err in limiting cross-examination of the Commonwealth's principal witness; (2) the trial court did not err in admitting a police officer's testimony, which, contrary to Defendant's assertion, did not improperly vouch for the principal witness's testimony; (3) the trial judge did not err in declining to sequester the police witnesses who were involved in the investigation and who had conducted interviews of the principal witness; and (4) the prosecutor did not improperly vouch for Commonwealth witnesses or misstate evidence during his closing argument. View "Commonwealth v. Ahart" on Justia Law

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Defendant filed a document in the county court entitled "Defendant-Appellant's Interlocutory Appeal on Confrontation Clause With a Known Confidential Informant - Sixth Amendment" that was not accompanied by copies of any relevant papers from the criminal case pending against Defendant in the district court. A single justice of the Supreme Court denied relief without a hearing. The full Supreme Court affirmed, holding that Defendant failed to meet his most basic obligations as an appellant in the full court because, among other things, his brief failed to contain adequate appellate argument, and his record appendix contained numerous items that were not before the single justice. View "Azubuko v. Commonwealth" on Justia Law

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Defendant was indicted for aggravated rape, indecent assault and battery, and other related offenses. The charges were based on five separate incidents involving five female victims. During the pretrial proceedings, the Commonwealth provided discovery to Defendant that included records related to medical treatment that some of the alleged victims received following the incidents. Defendant subsequently filed a motion for discovery that included the request for additional medical treatment or follow up visits any victim had pertaining to the indicted offenses. The superior court allowed the motion with respect to any follow up medical visits. The Commonwealth sought relief from that order, arguing that the order was improper because it required the Commonwealth to inquire of the alleged victims whether they sought or had follow-up treatment. The Supreme Court affirmed, concluding that the judge was only allowing Defendant's request to the extent it required the Commonwealth to provide information in its possession. View "Commonwealth v. Castillo" on Justia Law

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After a jury trial, Defendant was convicted of murder in the first degree on the theory of deliberate premeditation. Defendant appealed, arguing error in the admission of evidence, the prosecutor's closing argument, and the judge's instructions to the jury. The Supreme Court affirmed, holding (1) the trial court did not palpably err in admitting a 911 recording of the victim stating three times, "I've been stabbed"; (2) the prosecutor did not improperly attempt to evoke sympathy from the jury by playing, during his closing argument, the 911 recording; and (3) the trial court did not prejudicially err in its instructions to the jury on self-defense. View "Commonwealth v. Harris" on Justia Law

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Plaintiff received housing assistance through the Massachusetts rental voucher program. Plaintiff rented an apartment in Chelsea and received her voucher through the Chelsea Housing Authority. In 2009, Plaintiff received notice from the Authority that it was terminating her voucher because she did not report changes in family composition and in the family's income within thirty days of the change as required by the conditions of her voucher. After a hearing, the Authority's grievance panel upheld the termination. The Board of Commissioners affirmed, as did the superior court and appeals court. The Supreme Court reversed, holding (1) it was unlawful for the Authority to proceed to the grievance panel hearing without first offering Plaintiff the opportunity to engage in settlement negotiations; (2) the regulations Plaintiff was found to have violated were impermissibly vague; and (3) the grievance panel's factual findings were insufficient. Remanded. View "Rivas v. Chelsea Hous. Auth." on Justia Law

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After a jury trial, Defendant was convicted of kidnapping, assault by means of a dangerous weapon, assault and battery causing serious bodily injury, assault and battery, and malicious destruction of property. The court of appeals affirmed. The Supreme Court reversed Defendant's conviction of assault and battery causing serious bodily injury, holding that the evidence, which consisted primarily of medical records not explained by an expert witness, was insufficient to permit a rational jury to find that the victim suffered "serious bodily injury" within the meaning of the relevant statute. Remanded for resentencing on the remaining convictions. View "Commonwealth v. Scott" on Justia Law

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After a jury trial, Defendant was convicted of manslaughter. The principal question on appeal was whether, during a trial where the defendant raises a claim of self-defense and, pursuant to Commonwealth v. Adjutant, has been permitted to introduce evidence of the victim's prior violent acts on the issue of the identity of the first aggressor, the Commonwealth may introduce evidence of the defendant's prior violent acts on that same issue, to be followed by an instruction that the jury may consider the evidence of both parties' violent acts on the findings of who was the first aggressor. The Supreme Court answered yes, provided that the Commonwealth gives the defendant notice appropriately in advance of its intent to introduce such evidence and the trial judge determines that introduction of such evidence is more probative of its intended purpose than prejudicial to the defendant. In so answering, the Court affirmed the judgment of the trial court. View "Commonwealth v. Morales" on Justia Law

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In 2003, Plaintiffs filed a complaint against a police officer and city, alleging that, in 1999, the officer entered Plaintiffs' convenience store, arrested two of the plaintiffs, and beat all of the plaintiffs. Two of the plaintiffs were acquitted of criminal charges, but, in the meantime, Plaintiffs lost their business and suffered physical and emotional injuries. More than thirteen years after the incident and after a "tortuous" procedural history, the case arrived at the Supreme Court on limited further appellate review. In Jones II, the appeals court ordered the reinstatement of a 2004 default judgment against Defendants. The Court also had before it on direct appellate review an order of the superior court that amended the 2004 default judgment to correct a clerical error and that reinstated it. The Supreme Court (1) vacated the default judgment and remanded the matter for further proceedings to assess damages, holding that, under the circumstances here, a remand was necessary; and (2) vacated the amended judgment, holding that the superior court did not have jurisdiction to entertain a motion to amend the earlier default judgment, even to correct a clerical mistake, at the time the motion judge acted in 2012. View "Jones v. Boykan" on Justia Law

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Two sets of plaintiffs brought actions against the city of Worcester, alleging that the city was liable to them for nuisance, continuing nuisance, and continuing trespass arising from the discharge of effluent from the city's sewer system onto their properties. After the lower courts made a series of rulings in favor of the city, Plaintiffs appealed. The Supreme Court held (1) Plaintiffs' nuisance claims were not barred because they failed to satisfy the presentment requirement of the Massachusetts Tort Claims Act, as application of the presentment requirement in these cases would be egregiously unfair to Plaintiffs given that the law did not require presentment of nuisance claims at the time they filed their lawsuits; and (2) none of the statutory exceptions to sovereign immunity by the city was applicable in this case, and the city remained subject to suit. Remanded. View "Shapiro v. City of Worcester" on Justia Law