Commonwealth v. Obi, 58 N.E.3d 1014

Defendant Daisy Obi, a 70+ year-old landlord and Christian minister, was convicted in District Court of assault and battery for pushing tenant Gilhan Suliman (a Muslim woman) down a staircase, causing facial and shoulder injuries.
The jury trial focused on disputing credibility and whether Obi physically pushed Suliman; Suliman testified to prior religiously disparaging statements by Obi.
Obi was sentenced to 2 years in a house of correction (six months to serve, remainder suspended) and placed on probation with special conditions: (1) written disclosure to prospective tenants that she had a prior conviction and prior harassment prevention orders; (2) attendance at an introductory class on Islam; and (3) compliance with all federal/state laws including antidiscrimination/housing laws.
Obi appealed, arguing the jail term was disproportionate and that the probation conditions violated constitutional rights; she also challenged several trial rulings (including denial of a peremptory challenge and judge recusals).
The Supreme Judicial Court affirmed: it upheld the sentence length and the written-disclosure probation condition, declined to consider constitutional objections to the Islam class claim (waived on appeal), and rejected challenges to the peremptory strike and recusal arguments.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Proportionality of incarceration	N/A (Commonwealth sought sentence within statute)	Obi: 2-year term (six months to serve) is grossly disproportionate given age, first offense, and minor physical injuries	Sentence within statutory maximum and did not shock the conscience; not cruel or unusual — affirmed
Written disclosure to prospective tenants as probation condition	N/A	Obi: Violates art. 1 property rights and improperly burdens ability to rent/earn income; shame-based condition	Condition reasonably related to probation goals (public safety, deterrence, rehabilitation); burdens not excessive — upheld
Requirement to attend introductory class on Islam	N/A	Obi: Violates Establishment and Free Exercise Clauses (and cognate state rights)	Claim raised for first time on appeal and therefore waived; court did not address merits
Denial of peremptory challenge (juror wearing headscarf)	Commonwealth: challenge appeared motivated by juror's religion; prima facie case made	Obi: Counsel's stated reason (gut feeling juror unsympathetic) sufficed; judge erred in requiring a credible explanation	Judge found counsels' explanation inadequate; no abuse of discretion in denying the peremptory challenge

Commonwealth v. Goodwin, 414 Mass. 88 (court gives wide latitude in individualized sentencing)
Commonwealth v. Sanchez, 405 Mass. 369 (disproportionality standard and psychological harm considerations)
Commonwealth v. Jackson, 369 Mass. 904 (sentence must not shock conscience or offend human dignity)
Commonwealth v. Lapointe, 435 Mass. 455 (probation conditions must be reasonably related to sentencing goals)
Commonwealth v. Pike, 428 Mass. 393 (limits on probation conditions and unconstitutional restraints)
Commonwealth v. Power, 420 Mass. 410 (probation condition limiting profit from crime upheld; free-speech implication considered)
Commonwealth v. LaFrance, 402 Mass. 789 (probation condition authorizing blanket warrantless searches struck down)
Commonwealth v. Prunty, 462 Mass. 295 (peremptory challenge review; burden-shifting and sham explanations)
Commonwealth v. Issa, 466 Mass. 1 (analysis of protected-group exclusions in jury selection)
Commonwealth v. Maggio, 414 Mass. 193 (standard probation condition to obey all laws is permissible)