Justia Constitutional Law Opinion Summaries

After a jury trial, Defendant was convicted of murder in the first degree on theories of deliberate premeditation and extreme atrocity or cruelty. Defendant subsequently filed a motion for a new trial based on alleged trial errors. The motion was denied after an evidentiary hearing. The Supreme Judicial Court affirmed the order denying Defendant’s motion for new trial as well as Defendant’s conviction and discerned no basis to exercise its authority pursuant to Mass. Gen. Laws ch. 278, 33E, holding (1) the trial court erroneously admitted certain DNA evidence, but there was no substantial likelihood of a miscarriage of justice; (2) trial counsel was not ineffective for introducing audiotapes of prior consistent statements made by the Commonwealth’s principal witness for impeachment purposes; (3) there was no substantial likelihood of a miscarriage of justice created by the admission of a cooperating codefendant’s plea agreement without prior redaction; (4) there was no error in the admission of prior bad act evidence; and (5) trial counsel did not provide ineffective assistance. View "Commonwealth v. Lally" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on theories of deliberate premeditation and extreme atrocity or cruelty and of armed assault with intent to murder. The Supreme Judicial court affirmed Defendant’s convictions but vacated the trial court order denying Defendant’s first motion for a new trial, holding (1) the trial court did not err in admitting evidence of the decedent’s out-of-court statement about who had shot him; (2) the performance of Defendant’s first counsel was ineffective, and it is necessary to vacate the denial of Defendant’s first motion for a new trial and to remand the case for an evidentiary hearing to determine whether Defendant was prejudiced by his counsel’s deficient performance; and (3) any impropriety on the part of the prosecutor did not create a substantial likelihood of a miscarriage of justice. View "Commonwealth v. Celester" on Justia Law

Police officers applied for and obtained a warrant to search Defendant’s iPhone. The warrant authorized a search of Defendant’s iPhone for evidence of communications that would link him and another suspect to a shooting. The search resulted in the discovery and seizure of photographs of Defendant holding a gun. Defendant was subsequently charged with possession of a firearm without a license and related offenses. Defendant moved to suppress the photographs obtained from the search of his iPhone. The motion judge denied the motion to suppress, concluding that it was appropriate for the police to search the files on Defendant’s phone that contained his photographs. The Supreme Judicial Court affirmed, holding (1) because communications relating to and linking Defendant to the crimes under investigation would be found in photograph form on Defendant’s iPhone, a search of the photograph files was reasonable; and (2) the photographs at issue were properly seized as evidence linking Defendant to the crimes under investigation. View "Commonwealth v. Dorelas" on Justia Law

Defendant was on parole when his parole officer and others searched his apartment without a warrant and seized cocaine from his bedroom door. Defendant was indicted for possession of cocaine with intent to distribute. Defendant filed a motion to suppress the evidence seized from his home, arguing that the search was unconstitutional under both the United States and Massachusetts Constitutions. The motion judge allowed Defendant’s motion to suppress, holding that the search did not violate the Fourth Amendment but did violate article 14 of the Massachusetts Declaration of Rights. Specifically, the judge concluded that article 14 offers the same protections for parolees as it does for probations and that searches of a parolee’s residence must be supported by both reasonable suspicion and either a search warrant or a traditional exception to the search warrant. The Supreme Judicial Court vacated the allowance of Defendant’s motion to suppress, holding (1) article 14 does not offer as much protection to parolees as it affords to probationers, and therefore, reasonable suspicion is sufficient to justify a warrantless search of the parolee’s home; and (2) the officer in this case had reasonable suspicion that a search of Defendant’s home would produce evidence of a parole violation. View "Commonwealth v. Moore" on Justia Law

Defendant was stopped by a state police trooper, who was prompted by the receipt of an anonymous 911 call concerning an apparent drunk driver. After a bench trial, Defendant was convicted of operating a motor vehicle while under the influence of alcohol. Defendant appealed, arguing that the trial court erred in denying his motion to suppress the evidence obtained during the warrantless stop of his vehicle because the stop was neither supported by reasonable suspicion nor made pursuant to an ongoing emergency. The appeals court affirmed the denial of Defendant’s motion to suppress, concluding that the information bore sufficient indicia of reliability, and therefore, the trooper could rely on the information in establishing reasonable suspicion to conduct an investigatory stop. The Supreme Judicial Court affirmed, holding that the information gathered from the anonymous call, corroborated by other information, was sufficiently reliable to warrant a finding that the trooper had reasonable suspicion to stop Defendant’s vehicle. View "Commonwealth v. Depiero" on Justia Law

After a jury trial, Defendant was found guilty of murder in the first degree on the theory of deliberate premeditation. Defendant appealed, asserting, among other claims, that he was entitled to a new trial because he was denied his constitutional right to the effective assistance of counsel for two reasons. The Supreme Judicial Court affirmed Defendant’s convictions and declined to exercise its authority to order a new trial or to reduce the verdict of murder in the first degree, holding (1) counsel’s alleged errors were not likely to have influenced the jury’s conclusion; and (2) Defendant’s claims that various errors were made by the prosecutor and judge were without merit. View "Commonwealth v. Gonzalez" on Justia Law

After learning that two of the guests from a party at Defendant’s house were ill from ingesting tequila and that Defendant might also be ill, the police entered Defendant’s home to perform a well-being check under the “emergency aid” exception to the constitutional warrant requirement. While there, the police seized two tequila bottles, one of which was found to contain a so-called “date rape” drug. Defendant filed a motion to suppress, which the trial court denied. After a jury trial, Defendant was convicted of rape, drugging for sexual intercourse, and drugging to confine. The Supreme Judicial Court vacated the judgments of conviction, holding (1) the police had objectively reasonable grounds to believe that Defendant may be in need of immediate medical assistance, and therefore, the warrantless entry into Defendant’s home was justified; but (2) the seizure of the evidence was unreasonable because (i) it occurred after Defendant was transported to the hospital and while the police remained in his home without his consent, and (ii) the police seized the evidence for investigative purposes without verifying any demonstrable relationship to the emergency justifying their entry into Defendant’s home. Remanded for a new trial. View "Commonwealth v. Kaeppeler" on Justia Law

After a jury trial, Defendant was convicted of two counts of armed robbery, two counts of murder in the first degree, and one count each of home invasion, unlawful possession of ammunition, and possessing a firearm without a license. The Supreme Judicial Court affirmed the convictions and declined to exercise its authority pursuant to Mass. Gen. Laws ch. 278, 33E, holding (1) the trial court did not err in denying Defendant’s motion to suppress the firearm used in the armed robbery and murders; and (2) Defendant’s right to due process was not violated by the joinder of his trial with his codefendants and in the joinder of the armed robbery charges and charges relating to the home invasion. View "Commonwealth v. Hernandez" on Justia Law

Defendant was charged with malicious destruction of property over $250. The charge was based on the allegation that Defendant caused a security gate at his property to strike and damage the complaining witness’s (CW) vehicle. During discovery, Defendant filed a request for mandatory discovery of the CW’s criminal record. The probation department produced the unsealed entries in the CW’s criminal record but withheld the entries sealed pursuant to Mass. Gen. Laws ch. 276, 100A. Thereafter, Defendant filed a motion to compel production of the sealed criminal record. The judge denied the motion. Defendant subsequently filed this petition for review pursuant to Mass. Gen. Laws ch. 211, 3, claiming that mandatory disclosure required by Mass. Gen. Laws ch. 218, 26A and Mass. R. Crim. P. 14(a)(1)D) is not subject to an exception for sealed criminal records and that disclosure was necessary to effect his constitutional right to confrontation of the CW. The Supreme Judicial Court denied relief, holding (1) the mandatory discovery provisions of Mass. Gen. Laws ch. 218, 26A and Rule 14(a)(1)(D) do not apply to criminal records sealed pursuant to Mass. Gen. Laws ch. 276, 100A; and (2) Defendant failed to establish a constitutional right to disclosure for confrontation purposes. View "Wing v. Comm’r of Probation" on Justia Law

Defendant was convicted on four indictments alleging indecent assault and battery on a person with an intellectual disability in violation of Mass. Gen. Laws ch. 265, 13F. The crimes were alleged to have occurred between on or about January 1, 2008 and on or about September 16, 2011. On the effective date of November 2, 2010, the Legislature amended the statute substituting the term “mentally retarded person” with “person with an intellectual disability.” On appeal from the denial of his postconviction motions, Defendant asserted that the term “intellectual disability” renders Mass. Gen. Laws ch. 265, 13F unconstitutionally vague and that he was convicted under an ex post facto law. The Supreme Judicial Court affirmed, holding (1) Mass. Gen. Laws ch. 265, 13F, as amended, is constitutional; and (2) the convictions do not violate the ex post facto prohibitions of the Massachusetts Constitution or United States Constitution. View "Commonwealth v. St. Louis" on Justia Law