An unusual fact pattern led the Massachusetts Supreme Judicial Court to reverse a man’s murder conviction because the Commonwealth did not prove beyond a reasonable doubt that the murder happened in Massachusetts. The name of the case, which was delivered today, is Commonwealth v. Combs.
The facts established that the defendant and a man named Manny conspired to rob the victim. All three men were involved in the illegal drug trade. The victim picked up Manny from his job in Connecticut and they then drove to the defendant’s apartment in Springfield, Massachusetts. There was evidence that the victim was alive when he arrived in Springfield, including the defendant’s statement to the police that he had allowed “Manny’s friend” to use his bathroom. The defendant’s neighbor saw Manny drive the victim’s car over the grass and around to the backyard and then show an object in the backseat to Manny. When the defendant noticed his neighbor, he said his friend had come over to pick up some furniture. About half an hour after Manny and the victim arrived in Springfield, Manny and the defendant drove in different cars toward Connecticut. Manny drove the victim’s car (presumably carrying either the victim or the victim’s body) and the defendant drove his mother’s car. They arrived in Bloomfield, Connecticut, Manny got into the defendant’s car, and they drove away. The victim’s car was left in the parking lot. By this point, the victim had been strangled to death and his body was left in his car where it was discovered by local cops the following evening. The defendant’s DNA was discovered on the back seat of the victim’s car. The defendant gave a series of interviews to the police during which he acknowledged spending time with Manny and the victim, but denied being involved in the victim’s death. A Hampden County Superior Court jury convicted the defendant of first-degree murder. The defendant appealed, arguing that the Commonwealth had failed to prove the murder had occurred in Massachusetts. The Supreme Judicial Court agreed and reversed the defendant’s conviction.
Massachusetts law states that a murder conviction may be upheld only if the death occurred in Massachusetts or the defendant inflicted a violent or mortal wound against the victim in Massachusetts which led to the victim’s death in another state. The prosecution bears the burden of proving beyond a reasonable doubt that the death or the wound leading to the death happened in Massachusetts. In this case, the prosecutor argued the victim was strangled in the defendant’s Springfield apartment and then his body was transported to Connecticut. The SJC concluded the evidence supported the inference that the defendant was involved in a drug dealing scheme with the victim, that the victim was alive at the Springfield apartment, and that the victim’s body was later discovered in Connecticut. These facts, however, did not allow the jury to reasonably determine where the murder occurred.
Because the Commonwealth failed to prove territorial jurisdiction (that the crime happened in Massachusetts), the defendant’s murder conviction was reversed. Interestingly, Manny was also tried for murder in a separate trial and was found guilty. Manny’s conviction was upheld because in his case, the Commonwealth introduced statements Manny made to the police admitting that the victim had been assaulted in Massachusetts (and incurred injuries that had presumably led to his death). The different outcomes of these cases illustrates again that a person under investigation for committing a crime should not make a statement to the police without first consulting a criminal defense attorney.