Justia Constitutional Law Opinion Summaries

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on the theory of deliberate premeditation, holding that there was no prejudicial error in the proceedings below.After Defendant was convicted of murder, the Supreme Judicial Court reversed the conviction due to an error in the jury instructions. Following a retrial, Defendant was again convicted of murder. Defendant filed a motion for a new trial, which the trial court denied. The Supreme Judicial Court affirmed, holding (1) the trial judge's decision to allow a witness to avoid testifying at the second trial by invoking the privilege against self-incrimination and in admitting the witness's voir dire testimony, in lieu of live testimony at the second trial, did not create a substantial likelihood of a miscarriage of justice; (2) the trial court did not err in denying Defendant's motion for a new trial on the ground that he suffered from a mental disease or defect at the time of the shooting; (3) this Court again declines to extend its holding in Diatchenko v. District Attorney for the Suffolk District, 466 Mass. 655 (2013), to individuals over the age of eighteen; and (4) Defendant's arguments made pursuant to Commonwealth v. Moffett, 383 Mass. 201, 208-209 (1981) were unavailing. View "Commonwealth v. Johnson" on Justia Law

The Supreme Judicial Court vacated Defendant's guilty plea to a sentencing enhancement and his conviction of unlawful possession of a loaded firearm, holding that where a defendant makes a good faith claim that a deliberating juror reported that racial bias infected the jury's deliberations, a judge may not condition acceptance of a guilty plea to a sentencing enhancement upon a waiver of that claim.Immediately after entry of the guilty verdict in this case, a deliberating juror reported that racial bias influenced the jury's deliberations. Defendant filed a motion to investigate the juror's claims prior to the jury-waived trial on two sentencing enhancements. The prosecutor agreed to nol pros one sentencing enhancement in return for Defendant's guilty plea to the other sentencing enhancement if Defendant withdrew the motion. Defendant withdrew the motion and pleaded guilty to one of the sentencing enhancements. Defendant later moved, unsuccessfully, for a new trial, seeking to vacate his guilty plea to the sentencing enhancement. The Supreme Court ordered a new trial as to the sentencing enhancements, holding that once a defendant's right to a jury trial is invoked a defendant may not waive his right to a verdict that is untainted by racial or ethnic bias. View "Commonwealth v. McCalop" on Justia Law

The Supreme Judicial Court established a revised test for a court to determine whether a defendant seeking to suppress evidence based on a claim that a traffic stop violated equal protection principles.The Supreme Judicial Court reversed the judgment of the district court denying Defendant's motion to suppress the evidence seized from the vehicle he was driving, holding that the trial judge abused his discretion in denying the motion to suppress because Defendant produced sufficient evidence to raise a reasonable inference that the stop was racially motivated. In so holding, the Court concluded (1) a defendant seeking to suppress evidence evidence based on a violation of his or her equal protection rights must establish a reasonable inference that the officer's decision to initiate the stop was motivated by race or another protected class; and (2) to raise this inference, the defendant must point out specific facts from the totality of the circumstances surrounding the stop. View "Commonwealth v. Long" on Justia Law

The Supreme Judicial Court affirmed the denial of Defendant's motion to suppress evidence obtained as a result of a stop, holding that, going forward, the age of a juvenile suspect, if objectively apparent to a reasonable officer, will be part of the totality of the circumstances relevant to whether the juvenile as seized under article 14 of the Massachusetts Declaration of Rights.Minutes after a shooting, two police officers encountered seventeen-year-old Defendant walking on the sidewalk. After attempting to speak with Defendant, one of the officers started to get out of the cruiser, after which Defendant ran. Defendant was charged with murder in the first degree. Defendant filed a motion to suppress. The trial court denied the motion. The Supreme Judicial Court affirmed, holding (1) the trial judge did not abuse his discretion in concluding that the officers had a reasonable, articulable suspicion of criminal activity; (2) a child's age, when known to the officer or objectively apparent to a reasonable officer, is relevant to the question of seizure under article 14; and (3) there was insufficient evidence that the officers knew or should have known prior to his arrest, that Defendant was below the age of eighteen. View "Commonwealth v. Evelyn" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction, after a second jury trial, as a joint venturer in vaginal and anal rapes committed by his two coventurers, holding that subjecting Defendant to a second trial did not violate the constitutional protection against double jeopardy.Defendant was indicted on nine counts of forcible rape of a child. Defendant was charged as a principal in three of the rape counts and a joint venturer in three other counts. After a jury trial, Defendant was acquitted on the counts in which he was charged as a principal and all counts alleging oral rape where he had been charged as a joint venturer. The jury was unable to reach a verdict with respect to the remaining counts. At the retrial, the Commonwealth introduced the results of additional DNA tests conducted on the clothing the victim had been wearing. After a second jury trial, Defendant was convicted as a joint venturer in vaginal and anal rapes. The Supreme Judicial Court affirmed the convictions, holding (1) there was no error in retrying Defendant; and (2) the additional DNA evidence should not have been introduced at the second trial, but the error did not prejudice Defendant. View "Commonwealth v. Adams" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction for murder in the first degree and declined to grant extraordinary relief pursuant to Mass. Gen. Laws ch. 278, 33E, holding that there was no basis to set aside or reduce the verdict of murder in the first degree or to order a new trial.Specifically, the Supreme Judicial Court held that the trial judge did not err by (1) refusing to suppress Defendant's statements to police; (2) ruling against Defendant on two juror challenges pursuant to Commonwealth v. Soares, 377 Mass. 461 (1979); (3) excluding third-party culprit evidence; and (4) declining to instruct the jury in accordance with Commonwealth v. Reid, 29 Mass. App. Ct. 537 (1990). View "Commonwealth v. Rosa-Roman" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions for murder in the first degree, armed assault with intent to murder, and animal cruelty, and declined to grant extraordinary relief under Mass. Gen. Laws ch. 278, 33E, holding that no prejudicial error occurred.Specifically, the Supreme Judicial Court held (1) no error occurred during jury selection with respect to the voir dire of prospective jurors; (2) the judge did not abuse her discretion in finding that the neutral reason provided by the prosecutor for exercising a peremptory challenge was genuine and adequate; (3) the judge did not abuse her discretion in admitting prior bad act evidence, testimony that Defendant had access to firearms, and testimony regarding the results of a criminalist's Internet search; (4) evidence of charred paper fragments found in the basement of the dwelling where Defendant lived was not relevant, but the error was not prejudicial; and (5) there was no error in the prosecutor's statements during closing argument. View "Commonwealth v. Mason" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction for murder in the first degree, holding that any claimed instructional errors did not give rise to a substantial likelihood of a miscarriage of justice and that Defendant did not receive ineffective assistance of counsel.On appeal, Defendant argued that the trial court erred by failing to instruct the jury concerning a lack of criminal responsibility and mental impairment and erred by failing properly to instruct the jury that they could consider evidence of intoxication when determining whether a murder was committed with extreme atrocity or cruelty. Defendant further argued that trial court's failure to remedy the instructional errors deprived him of the effective assistance of counsel. The Supreme Judicial Court affirmed, holding (1) there was no error in the jury instructions and, accordingly no substantial likelihood of a miscarriage of justice in counsel's handling of the instructions; and (2) there was no reason to reduce the verdict to one of murder in the second degree. View "Commonwealth v. Santiago" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction for murder in the first degree on a theory of extreme atrocity or cruelty, holding that the errors that occurred during the trial did not require a new trial.On appeal, Defendant argued that she was prejudiced from the Commonwealth's use of prior bad act evidence. The Supreme Judicial Court affirmed, holding (1) some of the challenged evidence should not have been admitted, but there was no abuse of discretion int he judge's conclusion that the probative value of the evidence was not outweighed by its prejudicial effect; (2) the prosecutor's reliance on the prior bad act evidence in closing arguments was improper, but the improprieties did not so infuse the trial with unfairness as to deny due process of law; and (3) a reduction in the verdict pursuant to Mass. Gen. Laws ch. 278, 33E would not serve the interests of justice. View "Commonwealth v. Peno" on Justia Law

The Supreme Judicial Court reversed the denial of the motions to suppress filed by Nelson Mora and Ricky Suarez, holding that the continuous, long-term pole camera surveillance targeted at the residences of Mora and Suarez was a search under article 14 of the Massachusetts Declaration of Rights.Using video footage collected by hidden video cameras on public telephone and electrical poles (pole cameras) the Commonwealth secured indictments against twelve defendants, including Mora and Suarez. Eight defendants moved to suppress the pole camera footage and evidence derived from that footage as the fruits of an unreasonable search. The superior court denied the motions, concluding that the pole camera surveillance did not constitute a search. The Supreme Judicial Court reversed as to Mora and Suarez and remanded the matter to the superior court for further proceedings, holding that the warrantless surveillance of Mora's and Suarez's residences for more than two months was a "search" under article 14. View "Commonwealth v. Mora" on Justia Law