Justia Constitutional Law Opinion Summaries

In 2018, the Massachusetts Legislature enacted the "Tobacco Act," which prohibited the sale of tobacco products to anyone under 21 years old. The town of Brookline later passed an ordinance that divided potential tobacco consumers into two groups based on birth year: those born before January 1, 2000, and those born on or after that date. Retailers could sell tobacco products to the first group, but not the second. This effectively created an incremental prohibition on the sale of tobacco products in the town. Several retailers filed a lawsuit, claiming that the local law was preempted by the Tobacco Act and violated the equal protection provisions of the Massachusetts Constitution.The Massachusetts Supreme Judicial Court held that the local law was not preempted by the Tobacco Act. The court reasoned that the Tobacco Act expressly permitted local communities to limit and ban the sale of tobacco products. Furthermore, the local law did not conflict with the Tobacco Act's prohibition on sales to persons under 21; instead, it augmented this prohibition by further limiting access to tobacco products.The court also held that the local law did not violate the equal protection guarantees of the state constitution. The court found that the birthdate classification in the local law was rationally related to the town's legitimate interest in mitigating tobacco use, especially among minors. The court affirmed the dismissal of the retailers' complaint. View "Six Brothers, Inc. v. Town of Brookline" on Justia Law

The case concerns the constitutional rights of a criminal defendant, A.Z., who was involuntarily hospitalized for a competency determination under Massachusetts law, G. L. c. 123, § 15 (b). The Supreme Judicial Court of Massachusetts held that the involuntary commitment of a criminal defendant for a competency determination infringes upon a defendant's fundamental right to liberty and thus must satisfy strict scrutiny under the Massachusetts Declaration of Rights and the United States Constitution. To pass strict scrutiny, the involuntary commitment must be the least restrictive means available to vindicate the governmental interest at stake. Therefore, it is unconstitutional for a court to hospitalize a pretrial defendant for a clinical evaluation and observation of competency, absent a finding by the judge, by clear and convincing evidence, that hospitalization is the least restrictive means available to adequately determine a criminal defendant's competency to stand trial. The judge in this case did not make such findings, so the court concluded that the defendant's constitutional rights were violated. View "Commonwealth v. A.Z." on Justia Law

In this case, a Superior Court judge in Massachusetts sought guidance from the Supreme Judicial Court on three questions involving the pretrial confinement of a juvenile charged with murder. The juvenile, who was sixteen years old when he was charged with second-degree murder, was initially held without bail at a Department of Youth Services (DYS) facility due to a "courtesy" arrangement with the county sheriff. As the juvenile neared his eighteenth birthday, he was informed that he would be moved to an adult facility. In response, a Superior Court judge released him on personal recognizance on the murder charge and set bail on a related non-murder charge, ordering that he stay at the DYS facility.The Supreme Judicial Court of Massachusetts was asked to determine: 1) whether a Superior Court judge can commit a person under age eighteen charged with murder to DYS's care as a pre-trial detainee; 2) if not, can a Superior Court judge set bail on a charge related to, but other than murder, so that the person under eighteen is not held on bail on the murder charge and is committed to DYS's care; and 3) if the answers to questions 1 and 2 are "No," is the last paragraph of G. L. c. 119, § 68 (which mandates that juveniles charged with murder be committed to the custody of the sheriff) unconstitutional?The Supreme Judicial Court declined to answer the third question due to mootness, as the defendant had since turned eighteen and pleaded guilty to manslaughter. Regarding the first two questions, the court referred to its previous ruling in Nicholas-Taylor v. Commonwealth and affirmed that a Superior Court judge does not have the authority to commit a juvenile defendant charged with murder to the custody of DYS, nor can they sidestep this requirement by committing the juvenile to DYS on a related non-murder offense. Therefore, the answers to the first and second questions were "No." View "Commonwealth v. Padilla" on Justia Law

In this case, the defendant, Jason Robinson, was convicted of first-degree murder on a joint venture theory of felony-murder, with armed robbery as the predicate offence, in connection with the shooting death of Inaam Yazbek. Robinson appealed his convictions and the denial of his motion for a new trial, claiming insufficient evidence and trial errors.The Supreme Judicial Court of Massachusetts affirmed Robinson's conviction of murder in the first degree and the order denying his motion for a new trial. The court held that there was sufficient evidence to convict Robinson of felony-murder, as there was enough to permit an inference that Robinson knew that his co-defendant was armed during the commission of the armed robbery.The court also found no error in the admission of certain evidence, rejected Robinson's claim that he was prejudiced by being tried with his co-defendant, and found no error in the jury instructions, the exclusion of certain third-party culprit and police failure to investigate evidence, or in the prosecutor's opening statement and closing argument.However, the court ruled that Robinson's sentence of life without the possibility of parole was unconstitutional because he was nineteen years old at the time of the offense. The case was remanded for re-sentencing in line with the court's decision in Commonwealth v. Mattis. View "Commonwealth v. Robinson" on Justia Law

In this Massachusetts case, the defendant, Nyasani Watt, was convicted of first-degree murder and related offenses. After his conviction was affirmed by the Supreme Judicial Court of Massachusetts, he filed a motion for a new trial, alleging that his trial counsel had slept during critical portions of the trial, thus depriving him of his constitutional right to counsel. This motion was denied by a lower court judge without a hearing, and the denial was appealed to the Supreme Judicial Court.The Supreme Judicial Court determined that Watt had presented a new, substantial issue that it could not have considered in its previous review - namely, that his trial counsel had been sleeping during significant parts of the trial.Upon reviewing the evidence, which included affidavits from several people who had observed the trial counsel sleeping, the Court found that the trial counsel did indeed sleep through a significant portion of the trial and possibly during an important aspect of the trial. The Court held that this constituted a constructive deprivation of Watt's right to counsel under Article 12 of the Massachusetts Declaration of Rights.The Court further ruled that this error created a substantial risk of a miscarriage of justice and thus the defendant's convictions were vacated, the verdicts were set aside, and the matter was remanded to the Superior Court for a new trial. View "Commonwealth v. Watt" on Justia Law

In the case before the Supreme Judicial Court of Massachusetts, the defendant, Sheldon Mattis, was convicted of first degree murder among other charges, and was sentenced to a mandatory term of life in prison without the possibility of parole. At the time of the murder, Mattis was eighteen years old. He appealed his sentence, arguing that it was unconstitutional as applied to him because he was an "emerging adult" (defined in this case as eighteen, nineteen, or twenty years old at the time of the crime), and should be entitled to the same protection as juvenile offenders, who receive a term of life with the possibility of parole.The court considered whether their previous ruling in Diatchenko I, which concluded that sentencing a juvenile to life without parole in any circumstance would violate the Massachusetts Declaration of Rights, should be extended to apply to emerging adults. The court reviewed scientific evidence showing that the brains of emerging adults are not fully mature and are similar to those of juveniles, and also considered the treatment of emerging adults in Massachusetts and elsewhere.The court concluded that a sentence of life without the possibility of parole for emerging adult offenders violates the Massachusetts Declaration of Rights. As a result, the court invalidated the provisions of Massachusetts law that deny the possibility of parole to emerging adults. The court remanded the matter to the lower court for resentencing consistent with the court's opinion. The court also noted that this ruling does not suggest that emerging adults receiving the benefit of resentencing should be paroled once they have served a statutorily designated portion of their sentences. Instead, the parole board should evaluate the circumstances surrounding the commission of the crime, including the age of the offender, together with all relevant information pertaining to the offender's character and actions during the intervening years since conviction. View "Commonwealth v. Mattis" on Justia Law

In the case at hand, the defendant, Joshua Hart, and his girlfriend, Brittany Smith, entered the home of an elderly couple, Thomas Harty and his wife, Joanna Fisher, intending to steal their car and money. The couple ended up fatally attacking both Harty and Fisher, and then fled the state in the victims' vehicle. Hart was convicted on two counts of first-degree murder, and he appealed on several grounds.Hart argued that his confession to law enforcement was involuntary and should have been suppressed, but the Supreme Judicial Court of Massachusetts disagreed. The court found that Hart's confession was voluntary based on the circumstances of the interrogation, his experience with the criminal justice system, and his own actions and statements during the interrogation.Hart also argued that the trial should have been moved to another venue due to pretrial publicity. The court disagreed, stating that the defendant did not provide sufficient evidence to demonstrate that the pretrial publicity caused either presumptive or actual prejudice. The court found that less than 20% of potential jurors were excused due to pretrial publicity, and the judge took extensive steps to protect Hart's right to a fair trial.Hart further contended that a statement made by the deceased victim, Fisher, to her nurse, which was relayed to the jury through the nurse's testimony, should have been excluded from evidence as it was hearsay and violated his right to confront witnesses. The court determined that Fisher's statements were non-testimonial and thus did not violate the confrontation clause. The court also found that even if Fisher's statements were admitted in error, there was no prejudice because the Commonwealth presented other compelling evidence of the facts relayed in Fisher's statements.Finally, Hart argued that his sentences of life without the possibility of parole constituted cruel or unusual punishment because he was under 25 years old at the time of the crimes. The court rejected this argument, finding no reason to extend the prohibition of life sentences without parole for juveniles to individuals under the age of 25.Accordingly, the court affirmed Hart's convictions. View "Commonwealth v. Hart" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions for murder in the first degree based on a theory of felony-murder, among other charges, holding that a police officer's identification testimony was admitted improperly, but its admission did not prejudice Defendant.On appeal, Defendant challenged the denial of his motion to suppress, among numerous other allegations of error. For the claimed errors, Defendant requested that the court reduce his verdict or order a retrial. The Supreme Judicial Court affirmed, holding (1) a police officer's testimony identifying Defendant in a video recording at trial was improperly admitted, but the admission did not prejudice Defendant; and (2) Defendant was not entitled to relief on his remaining allegations of error. View "Commonwealth v. Fisher" on Justia Law

In this case involving a facility that operated under the protection of a thirty-six-year-old consent decree the Supreme Judicial Court held that the trial judge did not abuse her discretion in concluding that the Department of Developmental Services failed to establish that the consent decree should be terminated based on the evidentiary record before the probate court.In question was the treatment and welfare of individuals who suffered from severe developmental and intellectual disabilities that caused them to engage in grievous self-harm and other life-threatening behaviors. The individuals lived in group homes under the care of Judge Rotenberg Educational Center, Inc. (JRC), a facility that employed the use of aversive interventions such as electric skin shock as part of its treatment approach. In the 1980s and 1990s State agencies disrupted JRC's operations, after which the consent decree was issued. Years later, the agencies bound by the decree moved for its termination, but the probate and family court denied the motion. The Supreme Judicial Court affirmed, holding that the Department's arguments against continued enforcement of the consent decree were unavailing. View "Judge Rotenberg Educational Center, Inc. v. Commissioner of Dep't of Developmental Services" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of assault and battery by means of a dangerous weapon, holding that portions of the victim's then-girlfriend's grand jury testimony were properly admitted in accordance with the hearsay exemption for prior inconsistent statements.Prior to trial, the victim's then-girlfriend Shyla Bizarro identified Defendant as the victim's attacker from surveillance video footage and testified to her identification before the grand jury. Prior to her testimony, however, Bizarro revealed that she wished to recant her statements to police and her grand jury testimony. The trial judge admitted substantively the recanted portions of Bizarro's grand jury testimony, including her prior statements of identification. The Supreme Judicial Court affirmed the conviction, holding (1) the portions of Bizarro's grand jury testimony were properly admitted as prior inconsistent statements; (2) portions of Bizarro's grand jury testimony identifying Defendant in the video independently satisfied the hearsay exemption for statements of identification; and (3) there was no merit to Defendant's remaining arguments. View "Commonwealth v. Brum" on Justia Law