Justia Constitutional Law Opinion Summaries

In 2002, Defendant pleaded guilty to indecent assault and battery. In 2013, Defendant filed a motion to withdraw his guilty plea or for a new trial, arguing that his plea counsel was constitutionally ineffective by advising Defendant that he would need to “register” if he pleaded guilty to a sex offense without explaining the consequences of sex offender registration. The motion judge denied the motion, concluding that Defendant failed to establish that plea counsel was constitutionally ineffective. The Supreme Judicial Court affirmed, holding that plea counsel was not constitutionally ineffective in giving this advice in 2002, and the question of whether such advice would be constitutionally ineffective based on the current statutory scheme for sex offender registration is best left for another day. View "Commonwealth v. Sylvester" on Justia Law

Two telephone companies (collectively, Taxpayers) paid personal property taxes assessed by the board of assessors of Boston for fiscal year 2012 on certain personal property each company owned. Taxpayers subsequently filed abatement applications, which were denied. The Appellate Tax Board upheld the property tax assessments. Taxpayers appealed, arguing that the tax assessments, which were based on a split tax rate structure authorized by Mass. Gen. Laws ch. 40, 56, constituted a disproportionate tax that violated the Massachusetts Constitution. The Supreme Judicial Court affirmed, holding that the split rate structure authorized by section 56 and related statutes is not unconstitutionally disproportionate. View "Verizon New England, Inc. v. Board of Assessors of Boston" on Justia Law

Plaintiff, a Massachusetts prison inmate, brought civil rights action claiming that Defendants violated his constitutional right to due process by holding him in a special management unit (SMU) - or solitary confinement - for ten months without a hearing while waiting to reclassify or transfer him. The Supreme Judicial Court held that segregated confinement on awaiting action status for longer than ninety days gives rise to a liberty interest entitling an inmate to notice and a hearing. On remand, the superior court entered declaratory judgment in favor of Plaintiff and awarded him attorney’s fees and costs. Defendants appealed, arguing that Plaintiff was not a prevailing party under 42 U.S.C. § 1988(b) because he had been discharged from SMU detention long before he won any relief, and therefore, the declaratory judgment was moot and did not directly benefit him or materially alter his relationship with Defendants. The Supreme Judicial Court affirmed, holding (1) Plaintiff did qualify as a prevailing party in the circumstances of this case; and (2) the award of fees to Plaintiff was reasonable. View "LaChance v. Commissioner of Correction" on Justia Law

Defendant was stopped for failing to stop at a stop sign. The officer concluded that Defendant was using the vehicle without authority and decided to impound the vehicle. During an inventory search in preparation for impoundment, the officer seized a handgun and box of ammunition from the vehicle. Defendant was charged with unlawful possession of a firearm, unlawful possession of a loaded firearm, unlawful possession of ammunition without a firearm identification card, and unauthorized use of a motor vehicle. Defendant filed a motion to suppress the handgun, the ammunition, and statements he made to police. The municipal court allowed the motion to suppress. The Supreme Judicial Court affirmed the order allowing the motion to suppress, holding (1) the police did not have probable cause to believe that Defendant was operating the vehicle he was driving in violation of Mass. Gen. Laws ch. 90, 24(2)(a), and therefore, the impoundment of the vehicle was not proper; and (2) therefore, the inventory search was not lawful, and the handgun and ammunition were properly suppressed. View "Commonwealth v. Campbell" on Justia Law

Defendant was charged with murder in the first degree. A superior court judge allowed Defendant’s motion to suppress evidence recovered from his cellular telephone, concluding that the seizure of the telephone was not supported by probable cause. The Supreme Judicial Court affirmed, holding (1) probable cause to search or seize a person’s cellular telephone may not be based solely on an officer’s opinion or belief that the device is likely to contain evidence of the crime under investigation; (2) because the officers in this case lacked any information establishing the existence of relevant evidence likely to be found on Defendant’s telephone, the seizure was not supported by probable cause; and (3) the Commonwealth did not meet its burden of demonstrating that the sixty-eight-day-delay between the seizure and the application for a search warrant was reasonable. View "Commonwealth v. White" on Justia Law

After a jury trial, Defendant was convicted of two counts of criminal harassment. The convictions were based on five letters that Defendant wrote and sent to Michael and Susan Costello after a local election in which Michael had been elected as a town selectman. The Supreme Court reversed and dismissed Defendant’s conviction of criminal harassment of Michael and vacated Defendant’s conviction of criminal harassment of Susan and remanded for a new trial on that count, holding (1) in light of First Amendment constitutional protections afforded to political speech and the lack of evidence of serious alarm of Michael’s part, the evidence was not sufficient to support Defendant’s conviction of criminal harassment of Michael; and (2) the speech on which the complaint of criminal harassment of Susan is premised might be found to qualify as fitting within a constitutionally unprotected category of speech that may be subject to prosecution as a form of criminal harassment. View "Commonwealth v. Bigelow" on Justia Law

After a jury-waived trial, Defendant was convicted of unlawful possession of a firearm. Defendant appealed the denial of his motion to suppress a firearm and statements he made after his arrest, arguing that the police lacked reasonable suspicion to make an investigatory stop of him in connection with a breaking and entering that had occurred in a nearby home approximately thirty minutes earlier. The Appeals Court affirmed. The Supreme Judicial Court vacated the conviction, holding that the trial court erred in denying Defendant’s motion to suppress because the police lacked reasonable suspicion for the investigatory stop. Remanded. View "Commonwealth v. Warren" on Justia Law

After a jury trial, Defendant was convicted of operating a motor vehicle while under the influence of intoxicating liquor. The Supreme Judicial Court affirmed the conviction, holding (1) the trial court did not err in admitting evidence of Defendant’s failure to properly perform a breathalyzer test after giving consent, as the evidence was not inadmissible as refusal evidence; (2) the admission of the police-appointed interpreter’s English language version of Defendant’s statements did not violate the rule against hearsay, as the interpreter acted as Defendant’s agent under the circumstances of this case; (3) Defendant’s unpreserved confrontation claim was unavailing; (4) the evidence was sufficient to establish Defendant’s impairment; and (5) there was no prejudicial error in the jury instructions. View "Commonwealth v. Adonsoto" on Justia Law

The City of Springfield filed suit against the City of Papillion, and Sarpy County, seeking to enjoin Papillion from annexing land which had been indicated as Springfield’s area of future growth in a map adopted by the County in 1995. The district court for Sarpy County found that Springfield lacked standing; Springfield appealed. After review, the Nebraska Supreme Court found that Springfield asserted an infringement of its statutory governmental functions and rights under the County Industrial Sewer Construction Act. That infringement was sufficient to grant standing. The Court reversed the district court and remanded the case for further proceedings. View "Massachusetts v. Herndon" on Justia Law

Petitioners, Timothy Deal, Siegfried Golston, and Jeffrey Roberio, were juvenile homicide offenders serving mandatory indeterminate life sentences, and who had a constitutional right to a "meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation." At issue in this case was the manner in which juvenile homicide offenders were classified and placed in Department of Correction (department) facilities. Specifically, the issue was whether the department's practice of using "discretionary override codes" to block qualifying juvenile homicide offenders from placement in a minimum security facility unless and until the individual received a positive parole vote violated: (1) G. L. c. 119, section 72B (as amended by St. 2014, c. 189, section 2); or (2) their right to a meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation under the Eighth and Fourteenth Amendments to the United States Constitution, arts. 12 and 26 of the Massachusetts Declaration of Rights, or both Constitutions. After review, the Supreme Court concluded that the department's current classification practice violated G. L. c. 119, section 72B, because the department's failure to consider a juvenile homicide offender's suitability for minimum security classification on a case-by-case basis amounted to a categorical bar as proscribed by the statute. Furthermore, the Court concluded that the department's practice did not violate petitioners' constitutional right to a meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation because there was no constitutionally protected expectation that a juvenile homicide offender would be released to the community after serving a statutorily prescribed portion of his sentence. View "Deal v. Comm'r of Correction" on Justia Law