Commonwealth v. Cooley
477 Mass. 448
| Mass. | 2017Background
- On March 20, 2010, Nicholas Hiller was shot and killed while inside his vehicle in Springfield; the vehicle crashed and the victim later died from gunshot wounds.
- Edward Cooley was identified at the scene, admitted taking the victim’s cellphone and a paper bag (later found to contain marijuana), and was seen patting down the victim; he initially lied about several matters and hid a blood-stained leather jacket later shown to be his.
- The jacket had gunshot primer residue on the cuffs and blood matching the victim; phone records placed Cooley and the victim in contact with the same third number (ending in 7471) shortly before the shooting.
- The Commonwealth charged Cooley with first‑degree murder (felony‑murder predicated on armed robbery), unlawful possession of a firearm, and wilful interference with a criminal investigation; the jury convicted him on the murder and related charges.
- Cooley moved for a required finding of not guilty and later for a new trial based on nondisclosure of a police report in which Bryan Ingram allegedly said he shot the victim; the trial judge denied both motions and the SJC affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for felony‑murder (armed robbery predicate) | Commonwealth: circumstantial evidence (phone records, jacket with GSR and blood, taking of phone/bag, lies, concealment) shows Cooley was a joint venturer in an armed robbery that led to death | Cooley: evidence insufficient to prove intent to rob, knowledge of a gun, or taking property as part of a robbery; at most circumstantial | Court: Evidence sufficient; a rational juror could find intent, knowledge of a gun, and that Cooley completed the robbery as joint venturer or principal |
| Sufficiency for unlawful possession of a firearm | Commonwealth: possession of weapon inferred from GSR on jacket and planning to rob a drug dealer | Cooley: insufficient to prove he possessed or knew of a gun | Court: Denied required finding; GSR and context supported inference of possession/knowledge |
| Failure to disclose exculpatory police report (Ingram admission) — new trial motion | Commonwealth: nondisclosure acknowledged but evidence would not have changed jury’s verdict because main theory was joint venture and Ingram’s admission would show who shot but not that Cooley didn’t participate | Cooley: nondisclosed report was exculpatory and would have created reasonable doubt that he participated in the homicide | Court: Denial of new trial affirmed; nondisclosed report would more likely identify the coventurer than exonerate Cooley, so no prejudice shown |
| 33E review (reduce degree of guilt or grant new trial) | Commonwealth: convictions supported by record | Cooley: whole-record review should reduce or vacate conviction | Court: After review under G. L. c. 278, § 33E, convictions and denial of new trial stand |
Key Cases Cited
- Commonwealth v. Mendez, 476 Mass. 512 (standard for insufficiency review)
- Commonwealth v. Latimore, 378 Mass. 671 (evidence viewed in light most favorable to Commonwealth)
- Commonwealth v. Williams, 475 Mass. 705 (felony‑murder/armed robbery predicate principles)
- Commonwealth v. Zanetti, 454 Mass. 449 (joint venture concept and jury can differ on principal vs coventurer)
- Commonwealth v. Healy, 438 Mass. 672 (prejudice standard for nondisclosure/new trial)
- Commonwealth v. Ellison, 376 Mass. 1 (contrast where nondisclosure tended to show noninvolvement)
- Commonwealth v. Lao, 443 Mass. 770 (circumstantial evidence may suffice)
- Commonwealth v. Johnson, 463 Mass. 95 (inference from gunshot residue proximity)
- Commonwealth v. Vick, 454 Mass. 418 (consciousness of guilt evidence may support conviction)