Summary
The Supreme Judicial Court of Massachusetts affirmed the denial of Charles Jaynes’s petition for extraordinary relief under G. L. c. 211, § 3. The court held that review of an Appeals Court single justice’s order concerning removal or impoundment of prospective jurors’ names from the trial transcript was available through the ordinary appellate process, which Jaynes had already pursued.
Topics
Practice areas
Questions Presented
- Whether relief under G. L. c. 211, section 3, was available when Jaynes had an appeal to an Appeals Court panel as an adequate and effective avenue for reviewing the Appeals Court single justice's transcript-impoundment order.
- Whether the county court single justice abused her discretion or committed clear legal error by denying Jaynes's chapter 211, section 3, petition.
Holdings
- Relief under G. L. c. 211, section 3, is unavailable when the petitioner has an adequate and effective avenue other than section 3 for obtaining the requested relief.
- An order of an Appeals Court single justice concerning removal or impoundment of transcript materials is reviewable by an Appeals Court panel under the circumstances presented.
Key quotations
“Relief under G. L. c. 211, § 3, is available only in extraordinary circumstances.” (436 Mass. 1010)
“It is not available where the petitioning party has or had “adequate and effective avenues other than G. L. c. 211, § 3, by which to seek and obtain the requested relief.”” (436 Mass. 1010)
“The single justice’s decision to deny the petition for extraordinary relief was neither an abuse of discretion nor a clear error of law.” (436 Mass. 1010)
Factual background
During individual voir dire in a closed courtroom, the trial judge stated that the names of certain prospective jurors would be removed from the transcript for privacy reasons. The names were not removed, and an Appeals Court single justice subsequently ordered their removal based on the trial judge's representation to the jurors. Jaynes challenged that order through both an appeal to an Appeals Court panel and a chapter 211, section 3, petition.
Procedural history
At Jaynes's murder and kidnapping trial, the trial judge closed portions of individual voir dire and stated that prospective jurors' names would be removed from the transcript. The names were not removed, and the Appeals Court single justice later ordered their removal because the jurors had been told this would occur. Jaynes pursued an appeal from that order before an Appeals Court panel but also sought relief under chapter 211, section 3. The Supreme Judicial Court affirmed the county court single justice's denial because the Appeals Court panel appeal was an adequate and effective avenue of review.