Justia Constitutional Law Opinion Summaries

The Supreme Judicial Court reversed the trial judge’s denial of the Commonwealth’s renewed motion filed pursuant to Commonwealth v. Gelfgatt, 468 Mass. 512 (2014), and remanded for entry of an order compelling Defendant to enter a password into a cell phone seized from Defendant at the time of his arrest, holding that the motion judge abused his discretion in denying the Commonwealth’s motion.Defendant was charged with, among other things, trafficking a person for sexual servitude. The Commonwealth was granted a search warrant to search the cell phone found on Defendant, but the cell phone’s contents could only be accessed with the entry of a password. At issue was whether requiring Defendant to enter the cell phone’s password would violate his constitutional privilege against self-incrimination. A trial judge concluded that the Commonwealth failed to prove that Defendant’s knowledge of the password was a “foregone conclusion” under the Fifth Amendment to the United States Constitution and article 12 of the Massachusetts Declaration of Rights and denied the Commonwealth’s motion and renewed motion to compel Defendant to produce the password. The Supreme Judicial Court reversed, holding that Defendant’s knowledge of the password was a foregone conclusion and not subject to the protections of the Fifth Amendment and article 12. View "Commonwealth v. Jones" on Justia Law

The Supreme Judicial Court affirmed Defendant’s conviction of possession of a class B substance with intent to distribute, holding that although the voir dire in this case was incomplete, it did not prejudice Defendant.During jury selection, and over Defendant’s objection, the judge excused for cause a prospective juror who said that it was her opinion that “the system is rigged against young African American males.” On appeal, Defendant argued that the judge abused his discretion in dismissing the prospective juror. While the Supreme Court declined to set aside the verdict, the Court took the opportunity to set forth the factors a judge should consider when a prospective juror states a belief or opinion based on his or her world view. View "Commonwealth v. Williams" on Justia Law

The Supreme Judicial Court affirmed the order of the motion judge in this case allowing Defendant’s motion to suppress his postarrest statements, holding that the police lacked probable cause to arrest.Defendant was charged with receiving a stolen motor vehicle, subsequent offense, and receiving stolen property over $250 in connection with items found in a stolen motor vehicle. Defendant filed a motion to suppress his postarrest statements on the grounds that the police lacked probable cause to arrest. The motion judge allowed the motion. The Supreme Judicial Court affirmed, holding that there was insufficient evidence to establish probable cause that Defendant knew the vehicle was stolen, which is a requisite element of the crime of receiving a stolen motor vehicle. View "Commonwealth v. Pridgett" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court convicting Defendant of murder in the first degree on a theory of deliberate premeditation, holding that there was no reversible error in the proceedings below.Specifically, the Court held (1) the trial judge did not err in denying Defendant’s requests for an instruction on accident and on involuntary manslaughter; (2) the absence of an instruction on voluntary manslaughter did not create a substantial likelihood of a miscarriage of justice; (3) this Court was not required to apply the theory of transferred intent self-defense to correct a miscarriage of justice; (4) Defendant was not entitled to a new trial based on the erroneous deprivation of two preemptory challenges; (5) a police officer’s identification testimony, even if erroneous, was not prejudicial; and (6) trial counsel’s failure to present an intoxication defense through available witnesses did not constitute ineffective assistance of counsel. View "Commonwealth v. Pina" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendants Kevin McCormack and Brian Porreca of murder in the first degree, holding that there was no reversible error in the proceedings below.Specifically, the Court held (1) there was sufficient evidence to support each defendant’s murder conviction; (2) there trial judge did not err in concluding that there were no Brady violations; (3) there was no “newly discovered” evidence requiring a new trial; (4) Defendants’ rights to confrontation and due process were protected when a DNA expert testified at trial; (5) discovery violations in this case did not implicate the confrontation clause; (6) Defendants’ motion for disclosure of a confidential informant’s identity was properly denied; and (7) there was no reason for the Court to order a new trial or to reduce the degree of guilt under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Barry" on Justia Law

The Supreme Judicial Court affirmed Defendant’s conviction of involuntary manslaughter as a youthful offender, holding that the evidence proved that, by her wanton or reckless misconduct, Defendant caused the victim’s death by suicide and that Defendant’s conviction was not legally or constitutionally infirm.The trial judge concluded that Defendant’s act of encouraging the victim with text messages and phone calls to commit suicide and failure to act to overpowered the victim’s will to live and caused the victim’s death. The Supreme Court affirmed, holding (1) the evidence at trial was sufficient to establish Defendant’s guilt beyond a reasonable doubt; (2) Defendant’s verbal conduct was not protected by the First Amendment; and (3) the other legal issues raise by Defendant lacked merit. View "Commonwealth v. Carter" on Justia Law

The Supreme Judicial Court affirmed the judgment of a municipal court judge civilly committing M.C. for a period of two months, holding that the record contained sufficient evidence to support M.C.’s involuntary commitment and that M.C. was not denied due process of law despite the hearing being conducted at a hospital rather than at a court house and in the absence of a complete, verbatim transcript.Although M.C. sought to have the civil commitment hearing conducted at a court house, the hearing was held at the psychiatric facility where M.C. had been temporarily committed. At the beginning of the proceeding the court-owned recording equipment malfunctioned, and then two different alternate recording devices were used to record the remainder of the hearing. The Supreme Judicial Court affirmed the judge’s decision to civilly commit M.C., holding that the available transcript provided an adequate basis for appellate review and contained sufficient evidence to support M.C.’s involuntary commitment. View "In re M.C." on Justia Law

The Supreme Judicial Court affirmed Defendant’s conviction and the denial of Defendant’s motion for a new trial and declined to exercise its authority under Mass. Gen. Laws ch. 278, 33E to grant a new trial or to reduce the verdict, holding that there was no error or abuse of discretion in the proceedings below.Defendant was convicted of murder in the first degree. The Supreme Judicial Court affirmed, holding (1) the trial judge did not abuse her discretion in limiting Defendant’s cross-examination of the Commonwealth’s witnesses; and (2) the procedure suggested by the trial judge, and approved by defense counsel, of using two interpreters did not violate Defendant’s constitutional due process rights. View "Commonwealth v. Chicas" on Justia Law

The Supreme Judicial Court affirmed the superior court judge’s order vacating the district court judge’s Mass. Gen. Laws ch. 278, 58A (58A) pretrial detention order of David Barnes and affirmed the denial of William Scione’s petition for extraordinary relief, holding that Mass. Gen. Laws ch. 275, 23A (23A) does not qualify as a predicate offense under section 58A in its current form and that Mass. Gen. Laws ch. 266, 102A (102A) qualified in this case.Barnes was charged with violating section 23A, and Scione was charged with violating section 102A. In both cases, the Commonwealth moved to detain the defendants pursuant to section 58A, the pretrial detention statute. The Commonwealth’s motions were allowed and the defendants were ordered held. The Supreme Judicial Court affirmed the superior court judge’s order vacating the pretrial detention order of Barnes and affirmed the denial of Scione’s petition for extraordinary relief, holding (1) rape aggravated by age difference, section 23A, does not qualify as a predicate offense under section 58A; and (2) use of an incendiary device in violation of section 102A qualifies as a predicate offense under section 58A. View "Scione v. Commonwealth" on Justia Law

The Supreme Judicial Court affirmed Defendant’s conviction for unlawful possession of drugs found within a locked glove compartment, holding that the trial court did not err in denying Defendant’s motion to suppress and that Defendant was not deprived of the effective assistance of counsel.In denying Defendant’s motion to suppress the motion judge found that the police had probable cause to arrest Defendant for operating a motor vehicle while under the influence of marijuana and that the search of the vehicle was justified as an inventory search. The Supreme Judicial Court affirmed, holding (1) the trial judge was warranted in finding that police had probable cause to believe that Defendant had operated a motor vehicle while impaired; and (2) while the motion judge’s decision to deny the motion to suppress was improper on the grounds that the police conducted a lawful inventory search, the officers had authority to search the vehicle, pursuant to the automobile exception, for evidence pertaining to the offense of operating a motor vehicle while under the influence. View "Commonwealth v. Davis" on Justia Law