The Massachusetts Supreme Judicial Court today upheld the first-degree murder conviction for the resident of a group home who killed his counselor in 2011. The name of the case is Commonwealth v. Chappell.
In January of 2011, the defendant was living at Seagull House in Revere, which houses adults who suffer from mental illness. During the daytime hours of January 20th, the defendant and the victim were the only two individuals inside the house, as they were planning to attend an afternoon meeting with the victim’s supervisor. When the supervisor arrived at the house, the fire alarm was wailing and there was smoke coming from the building. Revere firefighters responded and found blood in the parking lot, blood in an interior hallway, and one of the victim’s boots. Underneath the defendant’s bed was a note he had written expressing interest in dating the victim. Below the defendant’s message, the victim had written that his note was inappropriate.
Within a couple of hours, the victim’s body was discovered in Lynn, near the defendant’s previous home. She was partially naked and wearing a boot that matched her boot left behind at Seagull House. Her body was covered by a sheet that was traced back to the defendant’s bedroom. She had been brutally beaten and her throat was slit, resulting in her death by massive blood loss. Following the victim’s murder, the defendant was seen near her car and appeared to have blood stains on his clothes. The police apprehended the defendant later in the day.
At the defendant’s trial, medical witnesses painted a bleak picture of his mental health history. He had been hospitalized several times in psychiatric wards. He was diagnosed with schizophrenia and began hearing voices and suffering from hallucinations. At one point, he was scared to leave his house. The defendant had a history of suffering from traumatic brain injuries, substance abuse, and lead poisoning.
The issue at the defendant’s trial was whether he was criminally responsible for the victim’s death. In Massachusetts, a defendant cannot be convicted of a crime if, at the time of the crime, he: (1) could not appreciate that his actions were unlawful; or (2) understood the unlawfulness of his conduct but was unable to prevent himself from committing the crime. The defense called expert witnesses who opined that the defendant was not criminally responsible and the Commonwealth countered with its own expert witness who testified the defendant was criminally responsible. The jury rejected the defendant’s mental health defense and convicted him of first-degree murder.
In his appeal, the defendant made a number of arguments that were rejected by the Supreme Judicial Court. The most interesting argument related to a jury instruction given by the trial judge regarding the consequences of the jury finding the defendant not guilty by reason of lack of criminal responsibility. The judge told the jurors if they acquitted the defendant because of his mental illness, he would be evaluated and could be committed to a mental institution if he was determined to be mentally ill and dangerous. However, pursuant to the law at the time, the judge did not tell the jury that the defendant could be committed to a mental hospital for the rest of his life. The SJC concluded it is appropriate for jurors to know how long a mental health commitment might last, and authored a new jury instruction that will be used in future cases. Unfortunately for the defendant, the Court determined there were no errors at his trial and his conviction and sentence were upheld.
Lack of criminal responsibility is a really hard defense because jurors are reluctant to absolve defendants of responsibility for horrific crimes. Hopefully the new jury instruction will provide proper guidance to jurors and allow them to understand that a not guilty verdict will not result in a mentally ill defendant’s release into the community.