Justia Constitutional Law Opinion Summaries

Articles Posted in Massachusetts Supreme Judicial Court
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The Supreme Judicial Court affirmed Defendant's convictions and the order denying his motion for a new trial and further declined to reduce the verdict of murder in the first degree to a lesser degree of guilt or to set aside the convictions under Mass. Gen. Laws ch. 278, 33E, holding that there was no prejudicial error in the proceedings below. Defendant was convicted of murder in the first degree on the theories of deliberate premeditation, extreme atrocity or cruelty, and felony-murder. The Supreme Judicial Court affirmed Defendant's convictions and the order denying his motion for a new trial, holding (1) the district court did not err in denying Defendant's motion to suppress his statements to police; (2) the trial judge did not err by declining to give a humane practice instruction sua sponte or by declining to provide the jury with complete instructions on joint venture; (3) the trial judge did not err in excluding certain hearsay evidence; and (4) the judge did not err in denying Defendant an evidentiary hearing on his motion for a new trial. View "Commonwealth v. Amaral" on Justia Law

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The Supreme Judicial Court vacated and set aside Defendant's convictions for murder in the first degree, armed assault with intent to murder, and firearm offenses, holding that four trial errors required that the verdicts be vacated and set aside and this matter remanded to the superior court for a new trial. Specifically, the Supreme Judicial Court held (1) the trial court erred in admitting a coventurer's statements against Defendant under the joint venture exemption to the hearsay rule, and admission of the statements was barred by the Sixth Amendment; (2) the trial court erred in admitting the opinion of the Commonwealth's gang expert, and the error was prejudicial; (3) the trial court erred in allowing police witnesses to give their opinions as to the identity of individuals depicted in surveillance footage; and (4) the prosecutor engaged in impermissible argument during closing, and a new trial was required. View "Commonwealth v. Wardsworth" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on theories of deliberate premeditation and extreme atrocity or cruelty, holding that there was no reversible error nor a reason to exercise its authority under Mass. Gen. Laws ch. 278, 33E to either reduce Defendant's convictions or grant a new trial. Specifically, the Court held (1) the trial judge did not err in declining to instruct the jury on voluntary manslaughter; (2) Defendant's age at the time of his crimes - nineteen years old - did not render his sentence of life imprisonment without the possibility of parole unconstitutional; and (3) the trial judge did not clearly err in refusing to grant a new trial due to a partial courtroom closure. View "Commonwealth v. Garcia" on Justia Law

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The Supreme Judicial Court affirmed Defendant's sentence of three consecutive terms of life imprisonment, with the possibility of parole after forty-five years, in connection with his conviction of three counts of murder in the first degree, holding that the sentence was within constitutional bounds. Defendant was a juvenile homicide offender and sought resentencing when he was well into adulthood. After the Supreme Judicial Court decided Commonwealth v. Costa, 472 Mass. 139 (2015), the Commonwealth conceded that Defendant was entitled to a resentencing hearing. After a hearing, the sentencing judge reinstated Defendant's sentence. Defendant then filed an application with the Supreme Court pursuant to Mass. Gen. Laws ch. 278, 33E for leave to appeal from the resentencing judge's ruling, as well as a motion for direct entry of the appeal. The single justice directed entry of the appeal on the question of whether a juvenile homicide offender may be required to serve forty-five years in prison before his first opportunity to seek release based on rehabilitation. The Supreme Judicial Court held that Defendant's sentence did not constitute cruel or unusual punishment in violation of article 26 of the Massachusetts Declaration of Rights. View "Commonwealth v. LaPlante" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the trial court denying Defendant's motion to suppress drug evidence, holding that the reveal of a plastic bag protruding from the cleft between Defendant's buttocks was within the scope of the lawful strip search and that the actions taken by the police were reasonable. During a lawfully strip search following Defendant's arrest, police officers caused Defendant to move a plastic bag from between his buttocks. The bag was revealed to contain individually wrapped plastic bags of heroin and cocaine. Defendant moved to suppress the drugs found in the plastic bag removed during the strip search. The trial court denied the motion. The Appeals Court reversed, concluding that the police were required under the circumstances to apply for a search warrant to remove the bag because they had failed to ascertain that "no portion of the bag was within Defendant's rectum," which search would require a warrant. The Supreme Judicial Court disagreed, holding that the motion to suppress was properly denied because the Commonwealth met its burden of showing that the protruding plastic bag was not lodged or embedded in Defendant's rectum and that its removal did not cause any manipulation of the rectum. View "Commonwealth v. Jeannis" on Justia Law

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The Supreme Judicial Court affirmed Defendant's convictions of murder in the first degree on the theories of felony-murder and extreme atrocity or cruelty and declined to grant extraordinary relief pursuant to Mass. Gen. Laws ch. 278, 33E, holding that there was no reason to grant a new trial or to either reduce or set aside the verdict. Specifically, the Court held (1) Defendant failed to show actual juror prejudice by way of pretrial publicity; (2) the judge did not abuse his discretion in admitting fingerprint evidence because the evidence was properly authenticated; (3) trial counsel did not provide ineffective assistance; and (4) the prosecutor's statements during closing argument did not amount to reversible error. View "Commonwealth v. Mack" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on theories of deliberate premeditation and extreme atrocity or cruelty and declined to exercise its extraordinary authority to afford relief under Mass. Gen. Laws ch. 278, 33E, holding that there was no error in the proceedings below warranting a new trial. On appeal, Defendant argued that, given his compromised medical and emotional state, the statements he made to police while he was in the hospital should have been suppressed and that the court should reduce the verdict to murder in the second degree. The Supreme Judicial Court affirmed the conviction, holding that no reversible error occurred in the proceedings below. View "Commonwealth v. Rivera" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the trial judge denying Defendant's motion for a new trial, holding that a defendant's waiver of his right to a jury of six persons need not be in writing as long as the trial judge ensures, by way of colloquy, that the defendant's decision to proceed is made knowingly and voluntarily. Defendant was convicted of cruelty to animals. During trial, one of the six jurors was excused from service. After conducting a colloquy, the judge found that Defendant knowingly and voluntarily waived his right to a jury of six persons, and the trial continued with five jurors. On appeal, Defendant argued that the trial judge erred in denying his motion for a new trial on the grounds that his waiver was invalid because it was not in writing pursuant to Mass. R. Crim. P. 19(b). The Supreme Judicial Court affirmed, holding that Defendant's waiver to his right to a six-person jury was valid. View "Commonwealth v. Bennefield" on Justia Law

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The Supreme Judicial Court Defendant's conviction of first degree murder and declined to exercise its extraordinary powers to grant relief under Mass. Gen. Laws ch. 278, 33E, holding (1) where a defendant facing trial on a charges of murder, sexual offenses against children, or rape requests individual voir dire on the issue of racial or ethnic prejudice and the defendant and the victim are of different such backgrounds, that request should be granted; but (2) a new trial was not required in this case. Specifically, the Court held (1) Defendant was not denied the right to a fair and impartial jury when, after members of the jury were exposed to an extraneous influence, the judge did not excuse the entire jury; (2) while the trial judge erred by partially excluding Defendant from the subsequent voir dire of the deliberating jury, Defendant was not prejudiced; (3) Defendant was not deprived of his right to a fair and impartial jury when the judge denied Defendant's request for individual voir dire on questions of ethnic bias; and (4) the judge did not abuse his discretion in certain evidentiary rulings. View "Commonwealth v. Colon" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction of murder in the second degree and the order denying his motion for a new trial, holding that Defendant's sentence was constitutional and that no prejudicial error occurred in the proceedings below. Defendant, who was seventeen years of age at the time of the murder, was sentenced to a mandatory term of life imprisonment with eligibility for parole after fifteen years. The Supreme Judicial Court disagreed, holding (1) a mandatory life sentence with parole eligibility after fifteen years for a juvenile homicide offender convicted of murder in the second degree is constitutional; (2) the judge did not err in denying Defendant's motion to continue his sentence so that he could present evidence related to his juvenile status; (3) the judge did not err in denying Defendant's request to instruct the jury on accident; (4) Defendant's counsel was not ineffective for not requesting other jury instructions; and (5) the judge did not err in denying Defendant's motion to suppress the warrantless "pinging" of Defendant's cellular telephone because no evidence came from the search. View "Commonwealth v. Lugo" on Justia Law