Justia Constitutional Law Opinion Summaries

At issue in this case was whether the crime of leaving the scene of an accident where death resulted requires the Commonwealth to prove that the defendant knew he collided with a person. Because the superior court judge initially agreed with the Commonwealth that it had no such burden, he found Defendant guilty. However, the judge allowed Defendant's motion for relief from judgment on the ground that the Commonwealth did have such a burden of proof, and ordered a judgment of acquittal to be entered. The Commonwealth appealed. The Supreme Court affirmed, holding that under Mass. Gen. Laws ch. 90, 24(2)(a 1/2)(2), the Commonwealth must prove the defendant knew he collided with or otherwise caused injury to a person. View "Commonwealth v. Daley" on Justia Law

After a jury trial, Defendant was convicted of unlawful possession of a firearm and unlawful possession of a loaded firearm. In addition, Defendant was convicted after a jury-waived trial of violating the armed career criminal statute. The only ammunition in evidence was that which was loaded in the firearm. The appeals court (1) reversed the convictions on the ground that certificates of ballistics analysis were admitted in violation of Defendant's constitutional right to confront witnesses against him; and (2) directed the entry of judgment for Defendant on the loaded firearm charge on the ground that, where he had been acquitted of possessing the ammunition that was loaded into the firearm, retrial on that charge would violate double jeopardy protections and principles of issue preclusion. The Supreme Court reversed in part, holding that Defendant's acquittal on the ammunition charge did not preclude retrial on the loaded firearm charge. View "Commonwealth v. Charles" on Justia Law

After a mistrial at which the jury was deadlocked, Defendant was retried and convicted of two indictments charging murder in the first degree on a theory of deliberate premeditation. The Supreme Court affirmed the convictions, holding (1) the trial court properly disallowed Defendant's claims that his motion to dismiss the indictments, filed before retrial, because the Commonwealth presented legally sufficient evidence at his first trial; (2) a second trial in these circumstances did not violate constitutional and common-law prohibitions against double jeopardy; (3) the trial judge did not err in his evidentiary rulings or in failing to instruct the jury pursuant to Commonwealth v. Bowden. View "Commonwealth v. Fitzpatrick" on Justia Law

Defendant was convicted by a jury of murder in the first degree, armed assault with intent to kill, assault with a dangerous weapon, and various firearms offenses. The Supreme Court affirmed Defendant's convictions and declined to grant him a new trial or to reduce the verdict to a lesser degree of guilt, holding (1) the trial judge did not abuse his discretion in allowing the peremptory challenge of an African-American juror; (2) the trial judge erred in admitting certain evidence concerning Defendant's juvenile record, but the error was harmless; (3) although some of the prosecutor's statements during closing argument may have exceeded the bounds of permissible argument, they were unlikely to have affected the jury's verdicts; (4) the trial judge did not err in concluding that Defendant was not entitled to an instruction on the use of force in defense of another; and (5) the trial court did not err in denying Defendant's motion for a new trial based on Defendant's assertion that he received ineffective assistance of trial counsel. View "Commonwealth v. Scott" on Justia Law

Petitioners, attorneys who were the subject of disciplinary proceedings, challenged the validity of two aspects of the Commonwealth's workers' compensation, claiming (1) Mass. Gen. Laws ch. 152, 7C, which authorizes the senior judge of the department of industrial accidents to suspend the right of an attorney to "practice or appear before the department," violated the separation of powers explicitly provided for under article 30 of the Massachusetts Declaration of Rights; and (2) 452 Mass Code Regs. 1.19(3), which precludes recovery of an employee's costs and attorney's fees if the employee does not accept an insurer's offer to pay the full amount of the compensation claim, conflicted with Mass. Gen. Laws ch. 15, 13A(5), which governs the award of attorney's fees and expenses where a claim proceeds to the hearing stage. The Supreme Court reversed in part, holding (1) chapter 152, section 7C is invalid as a violation of article 30 insofar as it authorizes the senior judge of the department to suspend attorneys from appearing before the department; and (2) section 1.19(3) is a valid interpretation of chapter 152, section 13A. Remanded. View "Ellis v. Dep't of Indus. Accidents" on Justia Law

A jury convicted of Defendant of being an accessory before the fact to murder. The Supreme Court reversed Defendant's conviction because the evidence did not establish that he had done any act before the assault to counsel, hire, or otherwise procure the assault. The Commonwealth subsequently sought and the grand jury returned an indictment charging Defendant with murder for his involvement in the killing. Defendant moved to dismiss the indictment, arguing that, because murder was a form, or a "species," of the lesser included offense of accessory before the fact to murder, a second prosecution was barred by double jeopardy. A judge denied the motion. The Supreme Court affirmed, holding (1) the indictment that charged Defendant with murder in the first degree did not violate the prohibition against double jeopardy; and (2) under the circumstances of this case, given the erroneous jury instructions and the erroneous admitted evidence, prosecution of Defendant for murder in the first degree was not barred on grounds of double jeopardy. View "Marshall v. Commonwealth" on Justia Law

After a jury conviction, Defendant was convicted of deliberately premeditated murder. The Supreme Court affirmed the conviction and declined to reduce the verdict or order a new trial, holding that the trial court did not err in (1) refusing to instruct the jury that they could consider evidence of voluntary intoxication on the question of Defendant's capacity to premeditate deliberately; (2) refusing to instruct the jury that they could return a verdict of voluntary manslaughter based on evidence of reasonable provocation or mutual combat; and (3) denying Defendant's motion for a new trial based on his claim of a closure of the court room during jury selection, as Defendant failed to meet his burden of showing there was a general or even a partial closure of the court room. View "Commonwealth v. Lennon" on Justia Law

A jury convicted Defendant of murder in the first degree on the theories of deliberate premeditation and extreme atrocity or cruelty, and of possession of a firearm without a license. The Supreme Court affirmed the order denying Defendant's motions to suppress and affirmed the judgments of conviction, holding (1) the pretrial judge did not abuse his discretion in denying Defendant's request for a continuance so that he could change counsel; (2) the trial court did not abuse his discretion in declining to allow Defendant to discharge his appointed counsel; (3) the trial court did not err in denying Defendant's motions to suppress statements; (3) the trial judge did not err in his instructions to the jury; and (4) there was no basis on which to grant Defendant relief pursuant to Mass. Gen. Laws 278, 33E by reducing the murder verdict to a lesser degree of guilt or granting Defendant a new trial. View "Commonwealth v. Delacruz" on Justia Law

At issue in this case was (1) whether a superior court judge erred in ordering the dismissal of an age discrimination complaint filed with the Massachusetts Commission Against Discrimination for lack of subject matter jurisdiction before a final decision had been reached by the commission, and (2) whether the ministerial exception required by the First Amendment prohibits a court or administrative agency from applying Massachusetts' antidiscrimination laws to the decision of a Jewish temple not to rehire a teacher in its Sunday and after-school religious school. The Supreme Court affirmed the dismissal of the complaint, holding (1) the judge erred in deciding whether the ministerial exception barred the discrimination claim before the commission had entered a final decision on the claim; but (2) the dismissal of the complaint was proper because the ministerial exception barred the teacher's claim of discrimination.

In two separate actions, seven Massachusetts hospitals and one managed health care organization that disproportionately provided medical care to the poor alleged that the Secretary of the Executive Office of Health and Human Services violated her obligation to reimburse them for the reasonable costs incurred in providing medical services to MassHealth enrollees. A superior court judge granted the Secretary's motion for judgment on the pleadings in one case and the Secretary's motion to dismiss in the other, concluding as a matter of law that the plaintiffs could not prevail even if their allegations were true. The plaintiffs appealed, and the cases were consolidated. The Supreme Court affirmed the decisions denying the plaintiffs' claims, holding that the plaintiffs' redress for their claims rested in the political arena, not in the courts.