Commonwealth v. Amran, 29 N.E.3d 188

Defendant and victim were in an arranged marriage; marriage deteriorated after defendant's affair and job loss; couple had a young son.
Victim disappeared Dec 31, 2008; defendant gave inconsistent accounts to family and police; body recovered Aug 17, 2009 from an embankment; remains were in advanced decomposition and contained morphine.
Defendant worked as a nurse at a facility that handled morphine and had access to morphine tablets seized from his apartment.
Defendant admitted moving and disposing of the body and prepared a confession letter for his girlfriend to copy; he testified at trial claiming the victim committed suicide.
Trial evidence included two postmortem photographs showing the body wrapped in plastic in a suitcase, a video-recorded police interview of the defendant (transcript provided to jurors), and disputed investigative materials; defendant convicted of murder with deliberate premeditation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of decomposed postmortem photos	Photos probative of consciousness of guilt, concealment, and to aid pathologist testimony	Photos were inflammatory, prejudicial, and not relevant to disputed issues	Admitted; judge acted within discretion per Nadworny; curative measures taken
Mistrial after ME testified "homicide"	ME's statement was an improper opinion that could prejudice jury; mistrial required	Curative instruction and striking the testimony cured prejudice	No mistrial; answer struck and curative instruction given; no abuse of discretion
Admission of unredacted police interview (accusations, references to other evidence, hearsay)	Portions should have been redacted as improper officer opinion, implication of extra evidence, and testimonial hearsay	Defense counsel strategically declined redactions to support Bowden-based attack on investigation	No reversible error; decision to admit unredacted portions was strategic; no substantial likelihood of miscarriage of justice
Failure to conduct broader voir dire after juror saw unredacted transcript pages	Judge should have conducted individual/collective voir dire per Jackson/Tennison	Only one juror saw limited text (one line); judge questioned foreperson and juror and found no extraneous influence	No abuse of discretion; no serious question of prejudice requiring further voir dire

Commonwealth v. Nadworny, 396 Mass. 342 (1985) (photographs of body location and decomposition probative of malice and consciousness of guilt)
Commonwealth v. Flebotte, 417 Mass. 348 (1994) (standard for reviewing admission of inflammatory evidence)
Commonwealth v. Santos, 463 Mass. 273 (2012) (police accusations in recorded statements improperly ask witnesses to assess credibility)
Commonwealth v. Spencer, 465 Mass. 32 (2013) (detectives' opinions accusing defendant of guilt are inadmissible)
Crawford v. Washington, 541 U.S. 36 (2004) (testimonial hearsay implicates Sixth Amendment confrontation rights)
Commonwealth v. Lannon, 364 Mass. 480 (1974) (use of term "homicide" by witness implies no legal liability but may intrude on jury function)
Commonwealth v. Chubbuck, 384 Mass. 746 (1981) (striking testimony and giving curative instruction can avoid mistrial)
Commonwealth v. Jackson, 376 Mass. 790 (1978) (procedure for addressing extraneous influence on jury)
Commonwealth v. Tennison, 440 Mass. 553 (2003) (reaffirming Jackson procedure for voir dire when extraneous material arises)
Commonwealth v. Bowden, 379 Mass. 472 (1980) (permitted defense argument attacking adequacy of police investigation)