Justia Constitutional Law Opinion Summaries

Articles Posted in Massachusetts Supreme Judicial Court
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The Supreme Judicial Court held that Defendant's right to choice of private counsel and right to be present during a critical stage of the proceedings under both the federal and state constitutions were violated during his criminal trial, requiring automatic reversal absent waiver, but that the delay of more than thirty years in bringing these claims under these circumstances waived the claims under state and federal constitutional law. In 1982, Defendant was convicted of murder in the first degree. In 2015, Defendant filed a second motion for a new trial asserting that the appointment of his court-appointed, State-funded counsel violated his rights under the Sixth Amendment and article 12 of the Massachusetts Declaration of Rights. The Supreme Judicial Court held (1) Defendant's right to choice of private counsel and right to be present during a critical stage of the proceedings under both the federal and state constitutions were violated, and these violations were structural errors; (2) the delay in bringing these claims combined with the fact that the transcript clearly depicting the constitutional violations was available for Defendant in 1991 and for the public defense counsel screening his claims in 1992-1993 and 2000 waived Defendant's claims; and (3) there was no substantial risk of a miscarriage of justice. View "Commonwealth v. Francis" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the single justice denying, without a hearing, Defendant's petition for relief under Mass. Gen. Laws ch. 211, 3, holding that the single justice neither erred nor abused his discretion by denying relief. After Defendant's motion to suppress was allowed, the Commonwealth applied for leave to prosecute an interlocutory appeal. A single justice allowed the application and directed the appeal to the Appeals Court. An interlocutory appeal was entered more than a year after the single justice granted the Commonwealth leave to appeal. Defendant filed a motion to dismiss the underlying charges, arguing that his speedy trial and due process rights had been violated. The motion was denied. Defendant then filed his Mass. Gen. Laws ch. 211, 3 petition seeking leave to cross-appeal from the denial of his motion to dismiss. The single justice denied relief. The Supreme Court affirmed, holding that Defendant did not show that the ordinary process of trial and appeal was inadequate for him to obtain review of his speedy trial and due process claims. View "Ramos v. Commonwealth" on Justia Law

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The Supreme Judicial Court affirmed Defendant's convictions for murder in the first degree and other crimes, affirmed orders denying Defendant's pretrial and postconviction motions, and declined to grant extraordinary relief pursuant to Mass. Gen. Laws ch. 278, 33E, holding that no reversible error occurred in the proceedings below. Specifically, the Supreme Judicial Court held (1) the trial judge did not err in deciding not to instruct the jury on self defense; (2) although it was error to require that Defendant's testimony take narrative form without his attorney's express prior invocation of Mass. R. Prof. C. 3.3(e), there was no substantial likelihood of a miscarriage of justice arising out of this error; (3) the trial judge did not err in denying Defendant's pretrial motion to dismiss the indictments; and (4) the trial judge properly denied Defendant's pretrial motion to suppress certain statements he made to officers at the police station without the benefit of prior Miranda warnings. View "Commonwealth v. Miranda" on Justia Law

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The Supreme Judicial Court affirmed Defendant's convictions for murder in the first degree and felony murder and declined to exercise its authority to reduce or set aside the murder verdict, holding that the record revealed no basis to support relief under Mass. Gen. Laws ch. 278, 33E. Specifically, the Supreme Judicial Court held (1) there was no error, constitutional or otherwise, regarding the manner in which defense counsel and the trial judge invoked Mass. R. Prof. C. 3.3 (e), as appearing in 471 Mass. 1416 (2015), and related procedures approved in Commonwealth v. Mitchell, 438 Mass. 535 (2003); (2) the trial court did not err by allowing the testimony of a substitute medical examiner; (3) the trial judge's failure to sever Defendant's trial from that of his codefendant did not result in prejudicial error; and (4) Defendant's conviction of and sentencing for both felony-murder, with attempted armed robbery as the predicate felony, and armed assault with the intent to rob did not violate the double jeopardy clause of the Fifth Amendment. View "Commonwealth v. Leiva" on Justia Law

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The Supreme Judicial Court affirmed Defendants' convictions and the orders denying their motions for a new trial and for postconviction relief but remanded the matter of Sheldon Mattis's sentence for an evidentiary hearing, holding that the record was insufficient to address the issue of whether a term of life without the possibility of parole for an individual between the age of eighteen and twenty-two years old violates the prohibition against cruel or unusual punishment. Defendants, Nyasani Watt and Sheldon Mattis, were convicted of murder in the first degree and related crimes. In addition to other claims, Mattis appealed from his mandatory sentence of life without the possibility of parole, arguing that, due to his age of eighteen, the sentence was unconstitutional. The Supreme Judicial Court held (1) there was no prejudicial error in the trial judge's challenged evidentiary rulings; (2) the judge did not err in failing to provide an involuntary manslaughter instruction; (3) remand was required for development of the record with regard to research on brain development after the age of seventeen; (4) the trial court did not err in denying Defendants' motions for a new trial; and (5) there was no reason to grant either defendant extraordinary relief pursuant to Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Watt" on Justia Law

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In this case brought by incarcerated individuals challenging the conditions of confinement during the COVID-19 pandemic the Supreme Judicial Court allowed the parole board's motion to dismiss only with respect to the claims of the individuals civilly committed and allowed the Governor's motion to dismiss, holding that the Governor was not liable under the facts alleged. The complaint alleged that by confining Plaintiffs under conditions that put them in grave and imminent danger of contracting the COVID-19 virus and by failing to reduce the incarcerated population, Defendants were violating Plaintiffs' right to be free from cruel and unusual punishment and their right to substantive due process. Further, Plaintiffs alleged that confining persons who have been civilly committed under Mass. Gen. Laws ch. 123, 35 in correction facilities violates the individuals' rights to substantive due process. The Supreme Judicial Court (1) granted the Governor's motion to dismiss, holding that the Governor's presence was not necessary to provide any relief that a court may order in this case; and (2) allowed the parole board's motion to dismiss only with respect to the claims of individuals civilly committed, holding that if Plaintiffs' constitutional claims were to prevail, the parole board would be a logical and necessary party to accomplish a reasonable remedial process. View "Foster v. Commissioner of Correction (No. 2)" on Justia Law

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The Supreme Judicial Court denied Plaintiffs' motion for a preliminary injunction enjoining the Department of Correction (DOC) from housing prisoners in facilities where the population exceeds its design-rated capacity and from housing prisoners areas where they must live within six feet of another person, holding that, despite the COVID-19 pandemic, Plaintiffs were unlikely to succeed on the merits of their claim for violations of the Eighth Amendment. Plaintiffs, incarcerated inmates serving sentences or individuals who were civilly committed under Mass. Gen. Laws ch. 123, 35, commenced a class action alleging that their conditions of confinement exposed them to unreasonable risks from the COVID-19 pandemic. Specifically, Plaintiffs alleged that Defendants' failure to take steps to reduce the incarcerated population so as to permit adequate physical distancing constituted cruel and unusual punishment in violation of the Eighth Amendment and violated substantive due process requirements. Plaintiffs sought a preliminary injunction in their claims for unconstitutional conditions of confinement because of the risk of a disease. The Supreme Judicial Court denied the motion, holding that Plaintiffs were unlikely to succeed on the merits of their claim. The Court then transferred the case to the superior court for a final adjudication on the merits. View "Foster v. Commissioner of Correction (No. 1)" on Justia Law

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The Supreme Judicial Court remanded this matter to the county court for entry of a judgment declaring that the Attorney General's decision to certify Initiative Petition 19-14, entitled "An Initiative Petition for a Law Relative to the Sale of Beer and Wine by Food Stores," was in compliance with the requirements of art. 48, The Initiative, II, 2 of the Amendments to the Massachusetts Constitution. After the initiative petition was submitted to the Attorney General, the Attorney General certified to the Secretary of the Commonwealth that Initiative Petition 19-14 was in proper form for submission to the people. Seven registered voters of the Commonwealth subsequently commenced an action in the county court challenging the certification of the initiative petition. The Supreme Judicial Court held that Initiative Petition 19-14 complied with article 48 because it neither contained unrelated subjects nor included a specific appropriation. View "Weiner v. Attorney General" on Justia Law

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The Supreme Judicial Court vacated certain portions of a trial judge's nondisparagement orders issued to the parties in this case in an attempt to protect the psychological well-being of the parties' minor child, holding that the nondisparagement orders here operated as an impermissible prior restraint on speech. After Mother filed for divorce from Father, Mother filed a motion for temporary orders, including a request that the judge prohibit Father from posting disparaging remarks about her and the ongoing litigation on social media. The judge issued temporary orders that included nondisparagement provisions against both parties. Thereafter, Mother filed a complaint for civil contempt alleging that Father violated the first order. A different judge declined to find contempt on the ground that the first order, as issued, constituted an unlawful prior restraint of speech in violation of Father's constitutional rights. The Supreme judicial Court agreed, holding that the nondisparagement orders were unconstitutional. View "Shak v. Shak" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree and the denial of his motion for a new trial and declined to exercise its authority under Mass. Gen. Laws ch. 278E to reduce Defendant's conviction to murder in the second degree, holding that Defendant was not entitled to relief on any of his allegations of error. Defendant was convicted of murder in the first degree on the theory of felony-murder. Defendant filed a motion for a new trial, which was denied. The Supreme Judicial Court affirmed, holding (1) Defendant's motion for a new trial was correctly denied because Defendant was not prejudiced by counsel's ineffective assistance; (2) this Court declines to extend the reach of the Court's holding in Commonwealth v. Brown, 477 Mass. 805 (2017), to Defendant's case; and (3) trial judge erred when he declined Defendant's request that the jury be instructed on the elements of voluntary and involuntary manslaughter, but the error was not prejudicial in the context of the judge's other instructions. View "Commonwealth v. Martin" on Justia Law