Commonwealth v. Chatman
466 Mass. 327
Mass.2013Background
- Defendant convicted of deliberately premeditated murder of his mother on January 24, 2002.
- May 6, 2008, defendant moved for a new trial alleging incompetence to stand trial; motion denied after a nonevidentiary hearing.
- On appeal, defendant challenges the failure to hold an evidentiary hearing and the denial of the motion, and seeks relief under G. L. c. 278, § 33E.
- Evidence at trial was circumstantial; defendant’s blood, fingerprint, and DNA evidence linked to the crime were contested.
- Expert affidavits from defense experts in 2009–2010 alleged long-standing mental illness; Commonwealth offered no expert contrary to those assertions.
- Judge conducted competency review, relied on trial observations, and found insufficient showing of incompetence; appellate focus is whether an evidentiary hearing is required.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Burden of proof for competency at motion for new trial | Commonwealth contends defendant bears burden to show incompetence by preponderance. | Chatman argues burden lies with Commonwealth to prove competence; defendant must show substantial doubt. | Burden misallocated; defendant must show Commonwealth would fail at trial; evidentiary hearing required. |
| Need for an evidentiary hearing on incompetence | Commonwealth argues no hearing warranted given record; no substantial issue. | Chatman asserts serious questions necessitate an evidentiary hearing. | Unusual circumstances and credible affidavits raise substantial issues; evidentiary hearing warranted. |
| Remedy for denial of motion for new trial | Commonwealth argues trial record supports denial of new trial. | Chatman seeks new trial or relief based on incompetence at trial. | Order denying the motion vacated and remanded for an evidentiary hearing; direct appeal deferred. |
Key Cases Cited
- Commonwealth v. Crowley, 393 Mass. 393 (Mass. 1984) (burden and standards for competency questions at trial and on motions)
- Commonwealth v. Hill, 375 Mass. 50 (Mass. 1978) (substantial doubt/competency standards context)
- Commonwealth v. Robbins, 431 Mass. 442 (Mass. 2000) (mental illness as a factor, not sole determinant of competence)
- Commonwealth v. Grace, 370 Mass. 746 (Mass. 1976) (deference to trial judge in motion for new trial context)
- Commonwealth v. Murray, 461 Mass. 10 (Mass. 2011) (standard for reviewing denial of motion for a new trial)
- Commonwealth v. Guerro, 14 Mass. App. Ct. 743 (Mass. App. Ct. 1982) (brief discussion relevant to evidentiary hearing standards)
- Commonwealth v. Banville, 457 Mass. 530 (Mass. 2010) (burden shifting when addressing suppression issues in motions)
- Drope v. Missouri, 420 U.S. 162 (U.S. 1975) (competence standards and right to consult counsel)