Justia Constitutional Law Opinion Summaries

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

The Supreme Judicial Court affirmed the superior court's order granting Defendant's motion to dismiss the cocaine and cash seized during a warrantless search of his residence, holding that Defendant's consent to a search of his residence did not purge the seizure from the taint of an illegal cell site location information (CSLI) search, where the consent was obtained through the use of information obtained from that search.The superior court ruled that the cash and cocaine must be suppressed because they were the fruits of unlawful police tracking of a cellular telephone through which the police obtained CLSI without a search warrant based on probable cause. The Supreme Judicial Court affirmed, holding (1) by monitoring the cell phone's CSLI, the police effectively monitored the movement of a vehicle in which Defendant was a passenger, thus giving Defendant standing to challenge the Commonwealth's warrantless CSLI search; (2) the seizure of the cocaine and cash was the direct result of information obtained from the illegal CSLI search; and (3) the Commonwealth failed to meet its burden of proving that the seizure was sufficiently attenuated from the illegal search such that it should not be deemed a forbidden fruit of the poisonous tree. View "Commonwealth v. Fredericq" on Justia Law

The Supreme Judicial Court reversed the motion judge's allowance of Defendant's motion to suppress, holding that police action causing an individual's cell phone to reveal its real-time location constitutes a search in the constitutional sense under article 14 of the Massachusetts Declaration of Rights, but, in this case, the warrantless search was supported by probable cause and was reasonable under the exigent circumstances exception to the search warrant requirement.After the police identified Defendant as the suspect in a murder case, the police contacted Defendant's cellular service provider to request the real-time location of Defendant's cell phone. They did so without a warrant. The service provider "pinged" Defendant's cell phone, which caused the cell phone to transmit its real-time GPS coordinates to the service provider. The GPS coordinates were relayed to the police, and the police were able to use that information to locate Defendant. Defendant moved to suppress the evidence as the fruit of an unlawful search. The motion judge allowed the suppression motion. The Supreme Judicial Court reversed, holding that the motion judge erred in concluding that the warrantless ping of Defendant's cell phone was not justified by exigent circumstances. View "Commonwealth v. Almonor" on Justia Law

The Supreme Judicial Court vacated in part and affirmed in part the decision of the Commonwealth Employment Relations Board upholding the Department of Labor Relations' (DLR) dismissal of Employees' challenges under the First Amendment to the exclusive representation and the mandatory agency fee provisions of the collective bargaining statute, Mass. Gen. Laws ch. 150E, holding that Employees' constitutional challenge to the agency fee provision was moot and that the First Amendment challenge to the exclusive representation provisions of the statute was foreclosed by Supreme Court precedent.While this case was on appeal, the United States Supreme Court held, in Janus v. American Federation of State, County & Municipal Employees, Council 31, 138 S. Ct. 2448 (2018) that all State agency fee laws violate the First Amendment by compelling nonmembers of public sector unions to support their unions' speech. The Supreme Judicial Court held (1) because the unions voluntarily stopped collecting agency fees to comply with Janus, Employees' agency fee provision challenge was moot; and (2) because the Supreme Court has deemed exclusive representation to be constitutional, Employees' challenge to the exclusive representation provisions of the statute were without merit. View "Branch v. Commonwealth Employment Relations Board" on Justia Law

The Supreme Judicial Court affirmed the district court's denial of Defendant's motion to dismiss the complaint charging unlawful possession of a firearm on constitutional grounds and denied Defendant's request for a new trial on the grounds of alleged errors in the jury instructions and asserted improper questioning of a witness by the prosecutor, holding that there was not a substantial risk of a miscarriage of justice in this case.Defendant, a firearm owner licensed to carry firearms in New Hampshire, did not obtain a Massachusetts firearm license within the statutory time period for new residents. Defendant was convicted of firearm-related offenses. The Supreme Judicial Court affirmed, holding (1) the trial judge did not err in denying Defendant's motion to dismiss where there was no doubt that Defendant lacked a Massachusetts firearm license and that Defendant could have applied for such a license within the statutory period filling his arrival in the Commonwealth; (2) Defendant suffered no prejudice from the jury instructions he challenged on appeal; and (3) the question the prosecutor posed to the witness in this case did not create a substantial risk of a miscarriage of justice. View "Commonwealth v. Harris" on Justia Law

The Supreme Judicial Court affirmed the motion judge's denial of Defendant's motion to suppress and Defendant's convictions of breaking and entering and larceny, holding that the Commonwealth's act of accessing and reviewing historical GPS location data recorded from a GPS monitoring device that was attached to Defendant as a condition of his probation was not a search in the constitutional sense.Specifically, the Court held (1) although the original imposition of GPS monitoring as a condition of Defendant's probation was a search, it was reasonable in light of Defendant's criminal history and apparent willingness to recidivate while on probation; (2) once the GPS device was attached to Defendant, he did not possess a reasonable expectation of privacy in data targeted by police to determine his whereabouts; and (3) the evidence was sufficient to support Defendant's convictions of breaking and entering in the nighttime and larceny over $250. View "Commonwealth v. Johnson" on Justia Law

In this criminal case, the Supreme Judicial Court held that, as applied to Defendant, GPS monitoring as a condition of Defendant's probation was an unconstitutional search under article 14 of the Massachusetts Declaration of Rights.Defendant was convicted of possession and distribution of child pornography. The terms of Mass. Gen. Laws ch. 265, 47 requires judges to impose GPS monitoring as a condition of probation for individuals convicted of most sex offenses. In accordance with the statute, the sentencing judge imposed GPS monitoring as a condition of Defendant's probation. Defendant appealed, arguing that, as applied to him, the condition of mandatory GPS monitoring constituted an unconstitutional unreasonable search. The Supreme Judicial Court agreed, holding (1) Mass. Gen. Laws ch. 265, 47 is over inclusive in that GPS monitoring will not necessarily constitute a reasonable search for all individuals convicted of a qualifying sex offense; (2) to comport with article 14, prior to imposing GPS monitoring on a defendant, a judge is required to conduct a balancing test weighing the Commonwealth's need to impose GPS monitoring against the defendant's privacy invasion arising by the monitoring; and (3) in the instant case, the Commonwealth's particularized reasons for imposing GPS monitoring on Defendant did not outweigh the privacy invasion that GPS monitoring entails. View "Commonwealth v. Feliz" on Justia Law

The Supreme Judicial Court affirmed Defendants’ convictions of murder in the first degree by reason of extreme atrocity or cruelty and felony-murder and declined to exercise its authority under Mass. Gen. Laws ch. 278, 33E to grant a new trial or to reduce the verdicts, holding that no prejudicial error occurred.The defendants in this case were Alexander Gallett and Michel St. Jean. The Supreme Judicial Court affirmed their convictions, holding (1) the motion judge did err in failing to suppress statements that Gallett made to police during his interrogation; (2) there was sufficient evidence to support St. Jean’s murder conviction; (3) St. Jean was not prejudiced by the admission of statements from Gallett’s redacted police interrogation; (4) the judge did not err in denying St. Jean’s requests for various jury instructions; (5) the trial judge did not improperly invoke juror sympathy; (6) there was no prejudicial error in limiting the cross-examination of certain witnesses; and (7) it was not reversible error for the judge to decline to give a humane practice jury instruction. View "Commonwealth v. Gallett" on Justia Law

The Supreme Judicial court affirmed the district court judge’s order allowing Defendant’s motion to suppress narcotics seized from Defendant’s crotch area as a result of a strip search that took place in a cell at a police station, holding that police did not have probable cause to believe that Defendant had concealed narcotics somewhere on his person so as to justify conducting a strip search.Specifically, the Court held that, based on the facts of this case, the officers had, at best, a reasonable suspicion that Defendant could be concealing contraband in his crotch, but because there was no affirmative indication that Defendant was secreting contraband in his groin area, the police lacked probable cause to conduct a strip search of Defendant. View "Commonwealth v. Agogo" on Justia Law

The Supreme Court affirmed the trial court’s grant of Defendant’s motion to suppress in this case concerning the scope of the emergency aid exception and the exigent circumstances exception to the warrant requirement.Defendant filed a motion to suppress evidence seized pursuant to a warrant on the ground that the warrant was predicated on observations made during an unconstitutional warrantless search. The superior court allowed the motion. The appeals court reversed, concluding that the warrantless search was permissible under the emergency aid doctrine. The Supreme Court granted further appellate review and affirmed the order allowing the motion to suppress, holding (1) the warrantless search was not justified under the emergency aid exception; and (2) the search was not justified under the probable cause and exigent circumstances exception. View "Commonwealth v. Arias" on Justia Law