In Commonwealth v. Aviles, a jury convicted the defendant of rape of a child and indecent assault and battery on a child under fourteen based on evidence that he sexually abused an eight-year-old girl living in his apartment. On appeal, the defendant challenged the admission of testimony about a later complaint made by the victim to her grandmother and a prior consistent statement from her grand jury testimony, arguing violations of the first complaint doctrine established in Commonwealth v. King. The Supreme Judicial Court affirmed the convictions, holding that the mother's testimony as the designated first complaint witness was properly admitted and that additional evidence served independent purposes. The court also modified the standard for reviewing trial court decisions on the admissibility of first complaint evidence to allow greater deference while clarifying that the doctrine does not bar otherwise admissible testimony. The ruling distinguished the facts from prior cases involving multiple escalating disclosures over time.
The case concerned Joseph Limone, who was charged with operating under the influence (seventh or subsequent offense) and related license violations after an off-duty Somerville police officer encountered him in Woburn following a minor car accident. Limone moved to suppress evidence obtained from the encounter, arguing that the off-duty officer's actions—ordering him out of the car, taking his keys, and directing him to wait—amounted to an unlawful extraterritorial arrest for a misdemeanor. The Superior Court denied the motion, Limone was convicted at trial, and the Appeals Court reversed, but the Supreme Judicial Court granted further review. The court affirmed the denial of suppression and the convictions, reasoning that the officer's conduct did not constitute an arrest because he did not investigate, collect evidence, or prevent the defendant from leaving on foot, and instead reasonably waited for local police as a private citizen.
This case concerns whether Francis Bevilacqua has standing to bring a try title action under Massachusetts law to compel Pablo Rodriguez to assert any claim to property at 126-128 Summer Street in Haverhill. Bevilacqua's claimed title derived from a quitclaim deed following a foreclosure sale conducted by U.S. Bank at a time when the mortgage had not yet been assigned to it by MERS. The Land Court judge raised the standing issue sua sponte and dismissed the complaint. The Supreme Judicial Court affirmed the dismissal, holding that Bevilacqua lacked standing because his chain of title rested on an invalid foreclosure that did not comply with the statutory power of sale requirements, but ordered the dismissal to be without prejudice.
The case involved charges against Mark D. Tremblay for malicious burning of personal property, damage to property for intimidation, and a civil rights violation stemming from the intentional burning of a neighbor's boat in 2002. After a jury convicted him on all counts, Tremblay appealed the denial of his motion to suppress statements made during a police interview, arguing that assurances by a state trooper that certain comments were 'off the record' rendered those statements involuntary. The Supreme Judicial Court of Massachusetts affirmed the convictions, holding that the statements were voluntary because the defendant was not in custody, was cooperative throughout the interview, and the circumstances did not show that the deception overrode his ability to make a rational choice about speaking. The court reasoned that the trooper's sympathetic demeanor, the non-coercive setting, and the defendant's relaxed and coherent state supported admissibility, distinguishing the facts from cases where fraud more directly undermined rational decision-making.
The case involved Jesse Maxwell, a workers’ compensation claimant, suing AIG Domestic Claims, Inc. (AIGDC) for referring his claim to the insurance fraud bureau, communicating with investigators and prosecutors, and allegedly using criminal processes for leverage, asserting claims including malicious prosecution, abuse of process, infliction of emotional distress, and violations of G. L. cc. 93A and 176D. The Supreme Judicial Court affirmed the Superior Court’s denial of AIGDC’s motion for summary judgment. The court reasoned that AIGDC possesses qualified immunity only for reporting potentially fraudulent activity under the relevant statute but not for communications with prosecutors or other conduct outside that scope, so the immunity does not bar all of Maxwell’s claims. It further held that while workers’ compensation exclusivity under G. L. c. 152 may bar portions of the claims, it does not entirely eliminate any single count and thus does not divest the court of jurisdiction.
The case concerned whether a District Court judge properly admitted a registry of motor vehicles certificate attesting that a notice of license revocation had been mailed to the defendant, in a prosecution for operating a motor vehicle after revocation for operating under the influence. The Commonwealth introduced the certificate without testimony from any registry witness. The court held that the certificate was testimonial evidence created for trial and its admission without cross-examination violated the defendant's Sixth Amendment confrontation rights. The error was not harmless beyond a reasonable doubt, so the conviction was reversed and the case remanded for further proceedings.