Justia Constitutional Law Opinion Summaries

The Supreme Judicial Court affirmed Defendant’s two convictions of murder in the first degree, holding that none of Defendant’s allegations of error warranted reversal. Specifically, the Court held (1) the pretrial motion judge did not err in denying Defendant’s motion to suppress statements he made to Canadian law enforcement officers; (2) the trial judge did not commit reversible error in ordering the pretrial disclosure of Defendant’s mental health expert’s report, which the prosecution had in its possession during its subsequent cross-examination of Defendant; (3) the evidence at trial did not demonstrate Defendant’s lack of criminal responsibility for the murders; (4) defense counsel did not provide ineffective assistance; and (5) State police investigators did not deny Defendant his right to a complete defense when they failed to collect certain evidence relevant to Defendant’s intoxication at the time of the crimes. View "Commonwealth v. Wright" on Justia Law

At issue was whether two grants of public funds to renovate an active church that had been identified as a “historic resource” under the Community Preservation Act, Mass. Gen. Laws ch. 44B, are categorically barred by the “anti-aid amendment” (see Article 18 of the Amendments to the Massachusetts Constitution, as amended by articles 46 and 103 of the Amendments), or whether the constitutionality of the grants must be evaluated under the three-factor test the Supreme Judicial Court has applied under Commonwealth v. School Comm. of Springfield, 382 Mass. 665, 675 (1981).The Supreme Judicial Court held (1) the constitutionality of the grants in this case must be evaluated under the three-factor test; (2) a grant of public funds to an active church warrants careful scrutiny; and (3) the judge applied this three-factor test incorrectly in denying Plaintiffs’ motion for a preliminary injunction to prohibit disbursement of these grants. View "Caplan v. Town of Acton" on Justia Law

At issue was whether two grants of public funds to renovate an active church that had been identified as a “historic resource” under the Community Preservation Act, Mass. Gen. Laws ch. 44B, are categorically barred by the “anti-aid amendment” (see Article 18 of the Amendments to the Massachusetts Constitution, as amended by articles 46 and 103 of the Amendments), or whether the constitutionality of the grants must be evaluated under the three-factor test the Supreme Judicial Court has applied under Commonwealth v. School Comm. of Springfield, 382 Mass. 665, 675 (1981).The Supreme Judicial Court held (1) the constitutionality of the grants in this case must be evaluated under the three-factor test; (2) a grant of public funds to an active church warrants careful scrutiny; and (3) the judge applied this three-factor test incorrectly in denying Plaintiffs’ motion for a preliminary injunction to prohibit disbursement of these grants. View "Caplan v. Town of Acton" on Justia Law

The police in this case had the authority to stop and perform a Terry-type search of a motor vehicle after an anonymous 911 caller reported that the driver of the vehicle threatened the caller, a fellow motorist, with a gun.Defendant, the driver of the vehicle at issue, was convicted of assault with a dangerous weapon. On appeal, Defendant argued that the police lacked probable cause to stop his vehicle, and therefore, the trial court should have suppressed the pellet gun found in his vehicle. The Appeals Court affirmed. The Supreme Court affirmed, holding (1) the information possessed by the police gave them reasonable, articulable suspicion to stop and perform a protective sweep of Defendant’s vehicle; (2) given the safety concerns of the police, reasonable suspicion was all that was required; and (3) therefore, the motion judge properly denied the motion to suppress. View "Commonwealth v. Manha" on Justia Law

The police in this case had the authority to stop and perform a Terry-type search of a motor vehicle after an anonymous 911 caller reported that the driver of the vehicle threatened the caller, a fellow motorist, with a gun.Defendant, the driver of the vehicle at issue, was convicted of assault with a dangerous weapon. On appeal, Defendant argued that the police lacked probable cause to stop his vehicle, and therefore, the trial court should have suppressed the pellet gun found in his vehicle. The Appeals Court affirmed. The Supreme Court affirmed, holding (1) the information possessed by the police gave them reasonable, articulable suspicion to stop and perform a protective sweep of Defendant’s vehicle; (2) given the safety concerns of the police, reasonable suspicion was all that was required; and (3) therefore, the motion judge properly denied the motion to suppress. View "Commonwealth v. Manha" on Justia Law

The Supreme Judicial Court affirmed the judgment of a single justice of the county court denying Appellant’s petition filed pursuant to Mass. Gen. Laws ch. 211, 3, holding that retrying Appellant after his first trial ended in a mistrial will not violate his protection against double jeopardy.Appellant was charged with murder in the first degree. After deliberating for several days, the jury reported that they were deadlocked. The judge determined that the deliberating and alternate jurors had improperly communicated and thus engaged in misconduct. Appellant filed a motion for a mistrial on this basis. The judge allowed the motion. Thereafter, Appellant filed a motion to dismiss the indictment. The judge denied the motion. Appellant then filed this petition seeking review of that decision. The Supreme Judicial Court affirmed, holding that because the evidence was legally sufficient to support a murder verdict against Appellant, retrying him will not violate the guarantee against double jeopardy. View "Pinney v. Commonwealth" on Justia Law

The Supreme Judicial Court declined, in this case, to depart from the tenet that a traffic stop constitutes a reasonable seizure for purposes of article 14 of the Massachusetts Declaration of Rights where a police officer has observed a traffic violation, notwithstanding the officer’s underlying motive for conducting the stop.The Supreme Judicial Court affirmed the denial of Defendant’s motion to suppress evidence seized during a traffic stop and affirmed Defendant’s conviction of unlawful possession of a controlled substance, holding (1) the stop at issue was justified based on the law enforcement officer’s observation of the vehicle speeding; (2) a question to the driver about the smell of marijuana did not fall beyond the permissible scope of the stop; and (3) the motion judge did not err in finding that the driver freely and voluntarily consented to the search of the vehicle. View "Commonwealth v. Buckley" on Justia Law

The Supreme Judicial Court declined, in this case, to depart from the tenet that a traffic stop constitutes a reasonable seizure for purposes of article 14 of the Massachusetts Declaration of Rights where a police officer has observed a traffic violation, notwithstanding the officer’s underlying motive for conducting the stop.The Supreme Judicial Court affirmed the denial of Defendant’s motion to suppress evidence seized during a traffic stop and affirmed Defendant’s conviction of unlawful possession of a controlled substance, holding (1) the stop at issue was justified based on the law enforcement officer’s observation of the vehicle speeding; (2) a question to the driver about the smell of marijuana did not fall beyond the permissible scope of the stop; and (3) the motion judge did not err in finding that the driver freely and voluntarily consented to the search of the vehicle. View "Commonwealth v. Buckley" on Justia Law

A driver’s consent to allow law enforcement officers to search for narcotics or firearms “in the vehicle” does not authorize the officer to search under the hood of the vehicle and, as part of that search, to remove the vehicle’s air filter.The superior court in this case granted Defendant’s motion to suppress, concluding that the scope of Defendant’s consent for officers to search for narcotics or firearms "in the vehicle" was limited to a search for narcotics or firearms in the vehicle’s interior and did not include a search under the hood beneath the air filter. The Supreme Judicial Court affirmed, holding that the search exceeded the scope of Defendant’s consent, and therefore, the search of the air filter under the hood was unconstitutional. The court thus affirmed the motion judge’s order allowing Defendant’s motion to suppress the weapons found in the air filter and Defendant’s subsequent statements to the police related to his possession of those weapons. View "Commonwealth v. Ortiz" on Justia Law

A driver’s consent to allow law enforcement officers to search for narcotics or firearms “in the vehicle” does not authorize the officer to search under the hood of the vehicle and, as part of that search, to remove the vehicle’s air filter.The superior court in this case granted Defendant’s motion to suppress, concluding that the scope of Defendant’s consent for officers to search for narcotics or firearms "in the vehicle" was limited to a search for narcotics or firearms in the vehicle’s interior and did not include a search under the hood beneath the air filter. The Supreme Judicial Court affirmed, holding that the search exceeded the scope of Defendant’s consent, and therefore, the search of the air filter under the hood was unconstitutional. The court thus affirmed the motion judge’s order allowing Defendant’s motion to suppress the weapons found in the air filter and Defendant’s subsequent statements to the police related to his possession of those weapons. View "Commonwealth v. Ortiz" on Justia Law