Massachusetts Supreme Judicial Court Affirms Murder Conviction in Framingham Domestic Violence Killing

The Massachusetts Supreme Judicial Court last week upheld the murder conviction and life sentence of a Framingham man who killed his wife after she became pregnant by another man and gave birth to his baby.  The name of the case is Commonwealth v. Alleyne

The defendant and the victim dated for several years and got married shortly after she graduated from high school.  Three months after their wedding, the victim gave birth to the defendant’s daughter.  Within a few months, the couple began having marital problems and the victim moved back in with her father.  She began a sexual relationship with her brother’s friend and became pregnant by him.  After becoming pregnant, the victim reconciled with the defendant and moved back in with him.  The victim gave birth and three days later the defendant and the newborn submitted to DNA testing which confirmed the defendant was not the father.  The victim decided to put the baby up for adoption, but the baby’s father said he wanted to raise the child.  The parties were in the process of completing the necessary paperwork when the victim was brutally stabbed to death.  After she had been missing for five days, the victim’s mother requested the Framingham Police Department do a well-being check at her apartment.  Framingham cops entered the apartment and found the victim’s decomposing body wrapped in a sleeping bag and blanket and surrounded by trash bags.  She had been stabbed 13 times.  Meanwhile, the defendant had fled to Mexico.  He was apprehended the following week as he reentered the United States.  He claimed he and the victim had argued and he left their apartment.  When he returned, he found the victim’s body and he ran because he knew he would be considered the prime suspect in her murder.  The defendant was convicted of first-degree murder and he appealed.

The most interesting appellate issue dealt with the Commonwealth’s introduction of 19 autopsy photographs that showed the victim’s gruesome injuries.  Some of the photos depicted close-up views of the wounds and other photos were taken from a “medium distance.”  In addition to the stab wounds, the photos also portrayed the decomposition of the victim’s body.  The defendant argued the admission of these photographs was inflammatory and unduly prejudicial to his case.  The Supreme Judicial Court acknowledged the risk of unfair prejudice in admitting autopsy photographs, particularly when the victim’s body has already started to decompose.  The question is whether it was important for the jurors to see the photos in order to resolve any contested fact in the case.  In this case, the Commonwealth was obligated to prove beyond a reasonable doubt that the defendant’s killing of the victim was premeditated and extremely atrocious or cruel.  The photos that showed the large number of stab wounds constituted relevant evidence on those points.  Further, as the photographs showed the victim’s body wrapped up and surrounded by trash bags, they were relevant to the defendant’s attempt to conceal the body (and probative, therefore, of his consciousness of guilt).  Because the judge asked potential jurors during the empanelment process if they would be able to remain impartial after viewing autopsy photos, and he instructed the jurors after closing arguments that they were not to be influenced by the graphic nature of the photos, any danger that the photos would be used inappropriately by the jury was mitigated.

The defense attorney did the right thing by trying to exclude (or at least limit) the introduction of autopsy photos, but as a practical matter a judge is going to allow the prosecutor to admit at least some photographic evidence of the appearance of the dead body.