Justia Constitutional Law Opinion Summaries

Articles Posted in Massachusetts Supreme Judicial Court
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The Supreme Judicial Court affirmed the judgment of the single justice of the court denying Petitioner's petition pursuant to Mass. Gen. Laws ch. 211, 3, holding that the single justice did not err or abuse her discretion in denying relief. Petitioner was charged with assault with a dangerous weapon, and, at arraignment, a judge ordered that Petitioner be committed to the state hospital for a determination whether he was competent to stand trial. After he had been committed Petitioner filed this Mass. Gen. Laws ch. 211, 3 petition alleging violations of his due process rights. The single justice denied the petition without holding a hearing. The Supreme Judicial Court affirmed, holding that Petitioner did not demonstrate why he was entitled to review pursuant to Mass. Gen. Laws ch. 211, 3. View "Howell v. Commonwealth" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the county court denying Defendant's petition for relief under Mass. Gen. Laws ch. 211, 3, holding that the single justice neither erred nor abused his discretion in denying relief. Defendant was indicted on charges of murder in the first degree and other offenses. The trial judge declared a mistrial because the jury were unable to reach a verdict on the murder charge. Defendant moved to dismiss the murder indictment and for a required finding of not guilty, arguing that a retrial was barred by double jeopardy principles because there was insufficient evidence to warrant a conviction. The trial court denied the motion. Defendant then filed a Mass. Gen. Laws ch. 211, 3 petition seeking relief from the denial of that motion. The single justice denied relief. The Supreme Judicial Court affirmed, holding that double jeopardy principles did not bar Defendant's retrial on the murder charge because the Commonwealth presented sufficient evidence to warrant a conviction of murder in the first degree based on extreme atrocity or cruelty. View "Collazo v. Commonwealth" on Justia Law

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The Supreme Judicial Court reversed the order of the motion judge denying Defendant's motion to suppress evidence found in his motor vehicle following a search, holding that the exit order that precipitated the search of the vehicle was unjustified. A search of a box hidden inside the front passenger seat of the vehicle at issue revealed a large amount of cocaine and several large stacks of cash. Defendant was subsequently charged with trafficking in cocaine. Defendant moved to suppress the evidence, arguing that the search took place after an unlawful exit order. The superior court denied Defendant's motion to suppress. The Supreme Judicial Court reversed, holding that because the exit order was not lawfully issued the evidence obtained from the subsequent search should have been suppressed as fruit of the poisonous tree. View "Commonwealth v. Barreto" on Justia Law

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The Supreme Judicial Court affirmed Defendant's convictions and the denial of his postconviction motions and declined to grant extraordinary relief pursuant to Mass. Gen. Laws ch. 278, 33E, holding that any error in the proceedings below was harmless. Defendant was convicted of murder in the first degree on the theory of deliberate premeditation and related charges. Before the Supreme Judicial Court was Defendant's appeal from his convictions, from the denial of his motion for a new trial, and from the denial of a motion to reconsider the denial of his new trial motion. The Supreme Judicial Court affirmed, holding (1) Defendant was not entitled to relief on his argument that newly discovered medical records warranted a new trial; (2) trial counsel was not constitutionally ineffective; (3) that the trial judge did not commit reversible error in admitting evidence of the defendant's prior, failed attempts to purchase a firearm; and (4) there was no reason for this Court to exercise its authority under Mass. Gen. Laws ch. 278, 33E to grant a new trial or to reduce or set aside the jury's verdict of murder in the first degree. View "Commonwealth v. Don" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction and the denials of Defendant's two motions for a new trial and declined to grant extraordinary relief pursuant to Mass. Gen. Laws ch. 278, 33E, holding that there was no error in the proceedings below. Specifically, the Court held (1) the trial court did not err by denying Defendant's motion for a required finding of not guilty; (2) Defendant did not receive ineffective assistance of counsel; (3) the trial judge did not err in admitting allegedly unduly prejudicial evidence, failing to sanction the Commonwealth for the alleged destruction of exculpatory evidence, and failing to recuse herself; and (4) because there was no error, any allegations of unpreserved cumulative error were without merit. View "Commonwealth v. Norris" on Justia Law

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The Supreme Judicial Court vacated Defendant's conviction of murder in the first degree and remanded the case, holding that errors in the closing argument constituted a miscarriage of justice requiring that Defendant's conviction not stand. After Defendant was convicted of murder in the first degree the Supreme Judicial Court remanded the matter to the superior court, where the Commonwealth was given a choice of either vacating the conviction and retrying Defendant on the murder indictment or accepting a reduction of the verdict to manslaughter. The Commonwealth chose to pursue a new trial. After the trial, the jury again convicted Defendant of murder in the first degree. The Supreme Judicial Court again remanded the matter to the trial court, where the Commonwealth again may accept a reduction in the verdict or manslaughter or retry Defendant on the murder charge, holding that errors in the closing argument that were reprised from the first trial and newly introduced required a new trial, and this determination was reinforced by other issues that emerged on the Court's review pursuant to Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Niemic" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on theories of extreme atrocity or cruelty and felony-murder and related crimes and declined to exercise its authority under Mass. Gen. Laws ch. 278, 33E, holding that there was no reason to reverse the convictions or to reduce the degree of guilt. Specifically, the Court held (1) Defendant was not deprived of his constitutional right to a competent interpreter to interpret the trial proceeding into his native language; (2) despite Defendant's arguments to the contrary, trial counsel provided effective assistance; (3) there was no error in the jury instructions as to joint venture liability, the merger doctrine, and the duty to find the highest crime proved beyond a reasonable doubt; (4) the trial judge did not abuse his discretion in making certain rulings concerning the conduct of the trial; and (5) there was no reason to order a new trial or to reduce the degree of guilt. View "Commonwealth v. Lee" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on a theory of felony-murder and the denial of his motion for a new trial and declined to grant relief under Mass. Gen. Laws ch. 278, 33E, holding that there was no reason to order a new trial or to reduce the verdict of murder in the first degree. On appeal, Defendant argued that a new trial was necessary because his trial counsel provided ineffective assistance. The Supreme Judicial Court affirmed Defendant's convictions and the denial of his motion for a new trial and declined to reduce the verdict under Mass. Gen. Laws ch. 278, 33E, holding that Defendant's counsel did not provide ineffective assistance and that there was no reason to order a new trial or to reduce the verdict of murder in the first degree. View "Commonwealth v. Colon" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction of possession of heroin with intent to distribute, reversed the denial of Defendant's motion for a new trial on the Mass. Gen. Laws ch. 94C, 32J (32J) charge, and vacated the conviction of a violation of section 32J, holding that counsel was ineffective in failing to challenge the sufficiency of the evidence regarding an essential element under section 32J. Defendant was convicted of possession of heroin with intent to distribute and with committing the crime within 100 feet of a public park, in violation of section 32J. The Supreme Judicial Court reversed in part, holding (1) the trial court did not err in denying Defendant's motion to suppress; (2) with respect to the "public park or playground" provision of section 32J, the intent to commit the underlying drug crime is sufficient, without additional proof of knowledge of park or playground boundaries required; (3) whether an area of land is a public park under section 32J is a question of fact properly left to the fact-finder; and (4) trial counsel was ineffective for failing to raise the variance between the park named in the indictment and the evidence presented at trial. View "Commonwealth v. Matta" on Justia Law

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The Supreme Judicial Court dismissed the Commonwealth's appeal from the trial court's allowance of Defendant's motion filed under Mass. R. Crim. P. 25(a), holding that the trial judge erred in reserving decision on Defendant's Rule 25(a) motion and that the error violated Defendant's right to due process and permeated the remainder of the trial. Defendant was charged with murder in the first degree. At the close of the Commonwealth's case Defendant moved for a required finding of not guilty pursuant to Rule 25(a). The judge reserved decision and submitted the case to the jury. The jury found Defendant guilty of murder in the second degree. Defendant subsequently renewed his motion under Rule 25(a). The judge allowed the motion, nunc pro tunc, to the close of the Commonwealth's case. The Commonwealth petitioned for relief under Mass. Gen. Laws ch. 211, 3. The Supreme Judicial Court denied relief, holding (1) in allowing the motion for a required finding nunc pro tunc after the jury returned their verdict the judge deprived the Commonwealth of its right to appeal from a postverdict acquittal; but (2) because the initial error in reserving decision on the motion implicated Defendant's constitutional rights and infected the remainder of the trial, the Commonwealth could not appeal. View "Commonwealth v. Yasin" on Justia Law