Justia Constitutional Law Opinion Summaries

A clerk-magistrate decided to allow public access to show cause hearings for individuals accused of being clients of a prostitution ring but denied media requests for the underlying complaint applications before the hearings. The accused individuals, referred to as John Does, intervened to oppose the public access decision and sought to keep the hearings private. The media outlets filed a petition in the Supreme Judicial Court for Suffolk County to challenge the clerk-magistrate's decision to withhold the complaint applications.The single justice of the Supreme Judicial Court remanded the matter to the clerk-magistrate for written findings on specific questions related to the public interest and privacy concerns. After reviewing the clerk-magistrate's responses, the single justice denied the petition, concluding that the clerk-magistrate did not commit an error of law or abuse her discretion in allowing public access to the hearings and denying access to the complaint applications.The Supreme Judicial Court affirmed the single justice's decision, holding that the clerk-magistrate acted within her discretion. The court found that the public interest in transparency and accountability outweighed the privacy interests of the accused, especially given the significant public attention and the potential for favoritism if the hearings were held privately. The court also agreed that denying access to the complaint applications was appropriate to prevent the dissemination of potentially erroneous or extraneous information before the accused had an opportunity to respond at the hearings.The court further directed the Trial Court to provide notice to the accused when a request for public access to a show cause hearing is made and to offer the accused an opportunity to respond before deciding on the request. View "Trustees of Boston University v. Clerk-Magistrate of the Cambridge Division of the District Court Department" on Justia Law

The defendant was convicted of sexual offenses against two minor girls, Kathy and Denise, who lived with him at the time of the alleged abuse. Kathy testified that the defendant touched her inappropriately on multiple occasions, including an incident where he allegedly penetrated her. Denise testified that the defendant sexually abused her in various ways, including touching and penetrating her. The defendant sought to introduce evidence of Denise's prior allegations of sexual abuse by a third party, arguing that the similarities between those allegations and her allegations against him suggested fabrication.The Superior Court judge excluded evidence of Denise's prior allegations under the rape shield statute, which generally bars evidence of a victim's past sexual conduct. The judge also prohibited cross-examination on this topic, reasoning that the evidence did not fall within any exceptions to the statute and that the policy of protecting victims, especially children, favored exclusion. The jury convicted the defendant on several charges, but acquitted him on others. The Appeals Court affirmed the convictions, and the defendant sought further appellate review.The Supreme Judicial Court of Massachusetts reviewed the case and held that the trial judge erred in excluding evidence of Denise's prior allegations of sexual abuse. The court found that the rape shield statute did apply to the evidence in question but concluded that the exclusion violated the defendant's constitutional rights to confront witnesses and present a complete defense. The court determined that the similarities between Denise's allegations against the defendant and her prior allegations were significant enough to warrant cross-examination. The court reversed the convictions and remanded the case for a new trial, emphasizing that the error was not harmless beyond a reasonable doubt given the centrality of Denise's testimony to the prosecution's case. View "Commonwealth v. Jacques" on Justia Law

F.A. has been involuntarily committed to state mental health facilities since 1999 after being found not guilty of a sexual offense due to mental illness. In 2020, a District Court judge renewed F.A.'s commitment and imposed a restriction confining F.A. to the buildings and grounds of the facility. F.A. challenged the constitutionality of this restriction.Previously, the Worcester Division of the District Court Department had renewed F.A.'s commitment annually and imposed similar restrictions since 2013. In 2020, F.A. opposed the Commonwealth's motion for the restriction, but the judge granted it after an evidentiary hearing. The judge did not require the Commonwealth to prove beyond a reasonable doubt that the restriction was necessary. In 2021, a different judge imposed the same restriction without an evidentiary hearing. The Appellate Division of the District Court affirmed the 2020 restriction but vacated the 2021 restriction due to the lack of a hearing. F.A. appealed the 2020 decision, and the Supreme Judicial Court granted direct appellate review.The Supreme Judicial Court of Massachusetts reviewed the case and found that the 2020 order violated F.A.'s substantive and procedural due process rights. The court held that a restriction under G. L. c. 123, § 16 (e) must be narrowly tailored to a compelling government interest and be the least restrictive means available. The judge failed to make such findings and did not consider less restrictive alternatives. Additionally, the court found that the judge used an incorrect standard of proof and did not provide timely, specific findings to support the restriction. Consequently, the court vacated the 2020 order. View "In the Matter of F.A." on Justia Law

The case involves the defendant, David E. Canjura, who was arrested by Boston police officers on July 3, 2020, after an altercation with his girlfriend. During a search incident to the arrest, officers found a spring-assisted knife on Canjura. He was charged with carrying a dangerous weapon under G. L. c. 269, § 10 (b), and assault and battery on a family or household member. Canjura conceded the knife met the statutory definition of a switchblade but challenged the constitutionality of the statute under the Second Amendment.In the Boston Municipal Court, Canjura filed a motion to dismiss the charge, arguing that the statute violated his Second Amendment rights. The judge denied the motion, and Canjura entered a conditional plea, reserving his right to appeal. The court accepted his plea and placed him on administrative probation, while the assault and battery charge was dismissed at the Commonwealth's request. Canjura appealed, and the Supreme Judicial Court of Massachusetts granted direct appellate review.The Supreme Judicial Court of Massachusetts reviewed the case and applied the two-part test from New York State Rifle & Pistol Ass'n v. Bruen. The court first determined that switchblades are "arms" under the Second Amendment, as they fit historical definitions and were commonly used for lawful purposes at the time of the founding. The court then examined whether the statute was consistent with the nation's historical tradition of arms regulation. Finding no historical analogues to justify the regulation of switchblades, the court concluded that G. L. c. 269, § 10 (b), violated the Second Amendment. The court reversed the denial of Canjura's motion to dismiss, vacated his admission to sufficient facts, and ordered judgment to enter for the defendant on the dangerous weapon charge. View "Commonwealth v. Canjura" on Justia Law

The defendant was convicted of first-degree murder for the stabbing death of his ex-girlfriend, Kathryn Mauke. The defendant and the victim had dated on and off for several years, but the victim ended the relationship in December 2014. On February 11, 2015, the defendant left work early, walked to the victim's home, and stabbed her thirty-two times. The defendant's primary defense at trial was that he was not criminally responsible due to mental illness, which the jury rejected.The case was initially tried in the Superior Court, where the defendant was found guilty of first-degree murder on theories of deliberate premeditation and extreme atrocity or cruelty. The defendant filed a motion for a new trial, arguing that the testimony of two incarcerated informants was unreliable and that his trial counsel was ineffective. The motion was denied by the same judge who presided over the trial. The defendant then appealed both his conviction and the denial of his motion for a new trial.The Supreme Judicial Court of Massachusetts reviewed the case. The court held that the testimony of the two incarcerated informants was permissible and declined to create a new rule requiring reliability hearings for such testimony. However, the court mandated supplemental jury instructions for future cases involving incarcerated informants. The court also found that the defendant's trial counsel provided effective assistance and that the prosecutor's statements during closing arguments were proper. The court concluded that the defendant's sentence of life without parole was unconstitutional based on a recent decision, Commonwealth v. Mattis, and modified the sentence to allow for parole eligibility after thirty years. The court affirmed the conviction and the denial of the motion for a new trial. View "Commonwealth v. Lacrosse" on Justia Law

Two non-domiciliary companies, S&H Independent Premium Brands East, LLC, and S&H Independent Premium Brands West, LLC, import and distribute European alcoholic beverages in the United States. They hold certificates of compliance under Massachusetts General Laws Chapter 138, Section 18B, allowing them to sell alcoholic beverages to licensed wholesalers in Massachusetts. In 2019, an Austrian malt beverage producer, Stiegl Getränke & Service GmbH & Co. KG, terminated its distribution agreement with S&H without prior notice and entered into a new agreement with another distributor, Win-It-Too, Inc.S&H filed a petition with the Alcoholic Beverages Control Commission (ABCC), alleging that Stiegl violated Massachusetts General Laws Chapter 138, Section 25E, which prohibits suppliers from refusing to sell to any licensed wholesaler without good cause. The ABCC dismissed the petition, stating that Section 25E protections apply only to wholesalers licensed under Section 18, not to certificate holders under Section 18B. S&H then sought judicial review in the Superior Court, which upheld the ABCC's decision, agreeing that Section 25E protections do not extend to Section 18B certificate holders.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the lower court's decision. The Court held that the term "any licensed wholesaler" in Section 25E refers only to wholesalers licensed under Section 18, not to certificate holders under Section 18B. The Court also concluded that this interpretation does not violate the dormant commerce clause of the United States Constitution, as Section 18B certificate holders and Section 18 licensed wholesalers serve different roles in the regulatory framework. Therefore, the ABCC's decision to dismiss S&H's petition was upheld. View "S&H Independent Premium Brands East, LLC v. Alcoholic Beverages Control Commission" on Justia Law

In November 2004, a sixteen-year-old juvenile stalked and robbed a victim at gunpoint, repeatedly raped her in her home, and then bound, gagged, and robbed her roommate when she arrived. He was sentenced to state prison for aggravated rape and other offenses, with a period of parole ineligibility compliant with constitutional requirements. After serving his prison term, he was placed on probation for the remaining nonhomicide offenses.In March 2007, the juvenile was adjudicated as a youthful offender and sentenced to sixteen to twenty years in state prison for aggravated rape, with additional concurrent and consecutive sentences for other offenses. In 2021, following a court decision, his sentence was restructured to comply with constitutional requirements, reducing his parole ineligibility to fifteen years. He was released from prison in January 2022 and began a five-year probation term. In August 2022, he was arrested for new offenses, leading to a probation violation notice and detention.The Supreme Judicial Court of Massachusetts reviewed the case. The court held that the restructured sentence, including the probation term, did not violate constitutional protections against cruel or unusual punishment. The court emphasized that the probation term provided the juvenile with an opportunity for rehabilitation and reintegration into the community. The court also noted that any potential further incarceration resulting from a probation violation would be subject to constitutional constraints, ensuring that the juvenile would not be treated more harshly than a juvenile convicted of murder for parole eligibility purposes. The court affirmed the order denying the juvenile's motion for relief from unlawful restraint. View "Commonwealth v. Sajid S." on Justia Law

A group of Massachusetts registered voters challenged the Attorney General's certification of Initiative Petition 23-12, which proposed "a Law Requiring the Full Minimum Wage for Tipped Workers with Tips on Top." The plaintiffs argued that the petition violated the requirement under art. 48 of the Amendments to the Massachusetts Constitution that initiative petitions contain only related or mutually dependent subjects. The petition proposed two changes: first, it would require employers to pay the full minimum wage to tipped employees, and second, it would permit tip pooling among both tipped and non-tipped employees.The plaintiffs commenced this action in the county court, claiming that the Attorney General's certification of the petition was in error because the petition did not contain only related or mutually dependent subjects. The single justice reserved and reported the case to the full court.The Supreme Judicial Court for the county of Suffolk affirmed the Attorney General's certification of the petition as in proper form to be submitted to voters. The court concluded that the petition, which would require that employers pay the full minimum wage to tipped employees and would permit tip pooling among both tipped and non-tipped employees, forms a "unified statement of public policy on which the voters can fairly vote 'yes' or 'no.'" The court found that the two provisions of the petition were closely related and shared a well-defined common purpose related to ending the existing compensation system common to tipped industries. View "Clark v. Attorney General" on Justia Law

The case involves Brandyn Lepage, who was convicted of first-degree murder on the theory of felony-murder. Lepage shot and killed Aja Pascual in her car on September 29, 2012. The police obtained call logs from the victim's phone, which showed that Lepage had called the victim shortly before her death. The police also obtained Lepage's cell phone records, including call detail records, historical cell site location information (CSLI), and ping data, without a warrant. Lepage appealed his conviction and the denial of his motion for a new trial, arguing that the police illegally obtained his cell phone records.The Superior Court Department had denied Lepage's pretrial motions to suppress the cell phone records. The court found that the police did not illegally obtain Lepage's call detail records and did not use the CSLI or ping data in the manner Lepage alleged. Lepage's motion for a new trial was also denied by the same judge who had previously denied his motions to suppress.The Supreme Judicial Court affirmed Lepage's conviction of murder in the first degree and the denial of his motion for a new trial. The court concluded that Lepage did not have a reasonable expectation of privacy in his call detail records, and therefore the police did not need a warrant to obtain this information. The court also found that the police did not use Lepage's CSLI or ping data to secure evidence against him. Therefore, the court concluded that there was no violation of Lepage's constitutional rights. However, the court vacated Lepage's conviction of unlawful possession of a firearm and remanded for a new trial on that indictment. View "Commonwealth v. Lepage" on Justia Law

The case revolves around Quasim Hastings, a prisoner convicted of second-degree murder in 2004 and eligible for parole consideration. Hastings, diagnosed with a mental disability, is entitled to a parole hearing that provides him with protections under the Massachusetts Constitution and Federal and State statutes prohibiting discrimination based on disability. Prior to a 2023 parole hearing, Hastings' counsel filed a motion for funds to retain a forensic psychologist and a social services advocate to assist with preparing a prerelease plan. While the motion for a forensic psychologist was approved, the request for a social services advocate was denied by a different Superior Court judge, who reasoned that the indigency statute limits his authority to approve funds to pending proceedings or appeals in any court.The judge's denial of the motion for funds was reported to the Appeals Court, and Hastings's application for direct appellate review was granted by the Supreme Judicial Court. The Supreme Judicial Court concluded that Hastings's motion for funds to retain a social services advocate implicates his State constitutional right to reasonable disability accommodations. Therefore, the constitutionally mandated exception to the indigency statute applies, and the order denying Hastings's motion for funds was reversed. The court held that a judge has the discretion to allow a motion for funds to pay for expert assistance as reasonably necessary to safeguard the indigent prisoner's constitutional rights prohibiting discrimination on the basis of disability. View "Commonwealth v. Hastings" on Justia Law