Justia Juvenile Law Opinion SummariesArticles Posted in Massachusetts Supreme Judicial Court
Commonwealth v. Ralph R.
The Supreme Judicial Court vacated and set aside Appellant's conviction as a youthful offender and his adjudications of delinquency, holding that the trial judge erred in failing to conduct an inquiry into the jury foreperson's report of "discriminatory comments" being made during deliberations.Appellant, a juvenile, was found guilty for two firearm-related offenses. On appeal, Appellant argued that his right to a trial by a fair and impartial jury was twice violated at his trial. The court of appeals agreed, vacated the judgment and adjudications of delinquency, and set aside the verdicts. The Supreme Judicial Court affirmed, holding (1) the trial judge abused his discretion by not conducting a preliminary inquiry into the foreperson's report that the jury remained capable of impartially rendering a verdict; and (2) because it cannot be determined whether comments reflecting racial, ethnic, or other improper bias were made and, if so, whether they created a substantial risk of a miscarriage of justice, the case must be remanded for further proceedings. View "Commonwealth v. Ralph R." on Justia Law
Rodriguez v. Mass. Parole Board
The Supreme Judicial Court affirmed the judgment of the superior court in favor of the parole board as to Plaintiff's appeal from the board's fourth denial of his request for parole, holding that the superior court correctly affirmed the board's decision to deny Plaintiff release on parole.After a retrial, Plaintiff was convicted of rape and assault and battery by means of a dangerous weapon for crimes he committed when he was sixteen years old. He was sentenced to life imprisonment with the possibility of parole. In denying Plaintiff's fourth request for parole, the board concluded that he was not yet rehabilitated and that his release was not compatible with the welfare of society. The superior court affirmed. The Supreme Judicial Court affirmed, holding that Plaintiff was not entitled to relief as to any of his arguments on appeal. View "Rodriguez v. Mass. Parole Board" on Justia Law
Nicholas-Taylor v. Commonwealth
The Supreme Judicial Court held that under the plain language of Mass. Gen. Laws ch. 119, 68 a juvenile defendant who is charged with murder and a properly-joined nonmurder offense must be committed to the custody of the sheriff if the defendant is not released on bail.Defendant, who was sixteen years old at the time of the offense, was charged with murder in the first degree and armed assault with intent to rob. At issue was whether the superior court judge had discretion to craft a bail order releasing Defendant on personal recognizance on the murder charge and ordering him to be held without bail on the related nonmurder charge such that he may continue to be held by the Department of Youth Services after his eighteenth birthday. The superior court judge concluded that he lacked the discretion to craft such a bail order and committed Defendant to the custody of the sheriff under Mass. Gen. Laws ch. 119, 68. The Supreme Judicial Court affirmed, holding that that plain language of the statute required that the superior court judge commit Defendant to the custody of the sheriff. View "Nicholas-Taylor v. Commonwealth" on Justia Law
Commonwealth v. Carson C.
The Supreme Judicial Court affirmed the judgment of the juvenile court judge denying Juvenile's motion to continue his arraignment for a competency evaluation and denying Juvenile's petition for expungement pursuant to Mass. Gen. Laws ch. 276, 100K(a)(5), holding that the juvenile court did not abuse its discretion.In two separate cases, Juvenile was charged with several offenses, including multiple counts of assault and battery by means of a dangerous weapon. Prior to arraignment, Juvenile filed a motion to continue so that he could undergo a competency evaluation and also filed a motion to dismiss. The judge denied the motions. Following an evaluation of Juvenile, the judge determined that Juvenile was incompetent to stand trial and was unlikely to become competent within the foreseeable future. The judge then dismissed all pending charges. Juvenile filed petition for expungement, which the juvenile court denied. The Supreme Court affirmed, holding that Juvenile was not eligible for expungement under Mass. Gen. Laws ch. 276, 100K(a)(5), and therefore, the juvenile court judge did not abuse his discretion in denying Juvenile's petition. View "Commonwealth v. Carson C." on Justia Law
Commonwealth v. Sharma
The Supreme Judicial Court vacated the denial of Defendant's Mass. R. Crim. P. 30(a) motion seeking to vacate his remaining sentences after he was paroled from his life sentence for murder and remanded the matter to the superior court for a hearing, holding that the motion judge failed to consider the specific circumstances and unique characteristics of Defendant as a juvenile.In 1996, Defendant, who was seventeen, committed crimes that resulted in his guilty plea to murder in the second degree, armed assault with intent to murder, and illegal possession of a firearm. Defendant was sentenced to life imprisonment for murder and two sentences of five to seven years' imprisonment for the assaults to run concurrent to each other but consecutive to the life sentence. After Defendant was paroled from his life sentence he moved to vacate the remaining sentences and for resentencing under Rule 30(a). The motion judge denied the motion. The Supreme Judicial Court remanded the matter to consider whether Defendant's sentences comported with article 26 of the Massachusetts Declaration of Rights, holding (1) 120 Code Mass. Regs. 200.08 distinguishes parole for life sentences from other sentences and is therefore invalid; and (2) because Defendant already served the aggregate minimum of his sentences, he was immediately entitled to a parole hearing. View "Commonwealth v. Sharma" on Justia Law
Commonwealth v. Fernandes
The Supreme Judicial Court affirmed Defendant's conviction for murder in the first degree but remanded for resentencing in accordance with Diatchenko v. District Attorney for the Suffolk District, 466 Mass. 655 (2013), holding that because Defendant was a juvenile at the time of the offense, resentencing was required.Defendant was sixteen years old when he shot and killed a fourteen year old boy. Defendant was convicted of murder in the first degree. In accordance with Mass. Gen. Laws ch. 265, 2, as the statute stood at the time of trial, Defendant was sentenced to life in prison without the possibility of parole. The Supreme Judicial Court (1) affirmed Defendant's convictions, holding that he was not entitled to relief on any of his allegations of error; and (2) pursuant to Diatchenko, held that Defendant should be resentenced so that he will be eligible for parole on his life sentence. View "Commonwealth v. Fernandes" on Justia Law
Commonwealth v. Ulani U.
The Supreme Judicial Court vacated the judgment of the juvenile court finding Juvenile in criminal contempt, holding that the juvenile court judge abused her discretion.Juvenile, who was sixteen years old, was before the juvenile court judge for a hearing on alleged violations of conditions of her release, called the judge a "dumb, white bitch." For this statement the judge found Juvenile in criminal contempt. Thereafter, the judge sentenced Juvenile to ninety days, the maximum sentence under rule 43. The Supreme Judicial Court vacated the judgment of contempt, holding that the judge abused her discretion by not taking into account Juvenile's status as a child when she imposed a ninety-day criminal sentence and did not comply with the requirements of Mass. R. Crim. P. 43 and 44. View "Commonwealth v. Ulani U." on Justia Law
Commonwealth v. Nick N.
The Supreme Judicial Court answered three questions reported by the juvenile court judge regarding waiver, evidentiary rules, and discovery procedures for hearings conducted under the procedures set forth in Wallace W. v. Commonwealth, 482 Mass. 789 (2019).Juvenile allegedly committed a major misdemeanor against another minor, followed by a minor misdemeanor against the same victim in a separate incident. The Commonwealth moved for a Wallace W. hearing to prove the greater offense, after which the juvenile court judge reported questions of law to the Supreme Court. The Supreme Court concluded (1) the Commonwealth may proceed directly to trial on the greater offense that preceded the first offense, but the Commonwealth may not arraign on the minor misdemeanor until it proves the greater offense; (2) a juvenile's failure to move for a prearraignment Wallace W. hearing on the first offense does not provide subject matter jurisdiction over the first offense; (3) the evidentiary rules laid out in Commonwealth v. During, 407 Mass. 108 (1990), apply to Wallace W. hearings; and (4) notice of the alleged violation and some exchange of discovery are required prior to Wallace W. proceedings. View "Commonwealth v. Nick N." on Justia Law
Dinkins v. Massachusetts Parole Board
The Supreme Judicial Court held that 120 Code Mass. Regs. 200.08(3)(c) (regulation), which concerns parole eligibility for inmates sentenced to a prison term that runs consecutive to a life sentence, is contrary to the plain terms of the statutory framework governing parole and is thus invalid.Plaintiffs, two inmates who were serving life sentences for murders committed when they were juveniles, sought declaratory relief invalidating the regulation. The superior court granted summary judgment in favor of the parole board, finding the regulation to be valid. The Supreme Judicial Court reversed, holding that by exempting sentences consecutive to a life sentence from the process often referred to as the "aggregation rule," the regulation contravenes the plain meaning of Mass. Gen. Laws ch. 127, 130 and 133. View "Dinkins v. Massachusetts Parole Board" on Justia Law
Commonwealth v. Terrell
The Supreme Judicial Court vacated the orders of the juvenile court judge requiring the Department of Youth Services (DYS) to credit the time that two youthful offenders spent detained in DYS custody prior to being adjudicated against their postadjudication confinement, holding that youthful offenders are not entitled to preadjudication detention credit like prisoners.Defendants were indicted as youthful offenders and held without bail in DYS custody. The judge committed each defendant to DYS custody until the age of twenty-one and ordered DYS to credit the time each spent detained in DYS custody prior to being adjudicated. The Supreme Judicial Court vacated the orders requiring preadjudication credit, holding that Mass. Gen. Laws ch. 218, 59 does not authorize a juvenile court judge to order preadjudication detention credit for youthful offenders pursuant to Mass. Gen. Laws ch. 279, 33A, which applies to criminal defendants. View "Commonwealth v. Terrell" on Justia Law