Massachusetts Supreme Judicial Court Upholds Conviction in Murder of Drug Dealer

The Massachusetts Supreme Judicial Court today affirmed the conviction of a man who was found guilty of participating in an armed robbery that resulted in the shooting death of a Springfield drug dealer.  The name of the case is Commonwealth v. Cooley

At just past midnight on March 20, 2010, witnesses heard gunshots in a Springfield neighborhood and saw two men running from the scene in opposite directions.  The victim, who was sitting in his car, had been shot in the chest.  Following the shooting, the victim’s car crashed through a fence and came to rest in a nearby yard.  Witnesses reported seeing the defendant, wearing a leather jacket, approach the victim’s car after the shooting and warn people not to call the police because the victim possessed marijuana.  The defendant entered the car and took the victim’s cellphone along with a bag from behind the seat in which the victim was sitting, before temporarily fleeing the scene.  Shortly thereafter, the police interviewed the defendant (who had returned without his leather jacket).  The defendant made a number of inconsistent or false statements about his interactions with the victim.  The police found his jacket hidden nearby and the cuffs tested positive for gunshot primer residue (suggesting a gun had been fired in close proximity to the jacket).  The jacket was also stained with the victim’s blood.  The police discovered the victim’s cellphone in the defendant’s girlfriend’s car, and the defendant admitted he had taken it after the shooting.  The defendant falsely told the police he had been talking to the victim on the phone at the moment of the shooting.  In fact, telephone records established the defendant had not spoken to the victim at all on the date of the murder although both men had shared telephone conversations with a mystery third party.  The defendant was ultimately arrested and charged with first-degree murder.  After a superior court jury found him guilty, he appealed and challenged the sufficiency of the evidence.

The Commonwealth’s theory of the case was that the defendant and another unidentified person had conspired to rob the victim.  During the robbery, either the defendant or his accomplice shot the victim.  The defendant was charged under the felony murder rule, which states that if someone dies as a result of the defendant’s participation in the commission of a felony (such as armed robbery), the defendant is guilty of murder.  The defendant here argued there was insufficient evidence to establish he had been involved in robbing the victim before his death.  The Supreme Judicial Court disagreed.  The Court said the defendant knew the victim was a drug dealer and had admitted to searching for the victim’s marijuana moments after the shooting.  Further, the pattern of phone calls between the defendant and the mysterious potential accomplice around the time of the murder allowed the jury to infer a nefarious plan was put in place by the defendant.  The Court also reasoned the evidence established the defendant either had a gun or knew his accomplice had a gun and were planning to use the gun to rob the victim, who was known to carry large amounts of marijuana and cash.  Finally, by taking the victim’s phone and bag, the defendant had arguably completed the robbery.

The defendant was sentenced to the mandatory sentence of life in prison without the possibility of parole, which is a bit unsettling given the underwhelming nature of the Commonwealth’s evidence.