Commonwealth v. Donovan E. Goparian, 262 N.E.3d 948

Donovan E. Goparian was convicted in 2020 of murdering Marie Martin, whose charred body was found in a burned car in Worcester in 2015.
The case against Goparian was built on circumstantial evidence and testimony from witnesses with credibility issues, including individuals who later admitted to lying or had cooperation agreements with the state.
During trial, late-breaking evidence emerged: statements from a federal inmate (Nuzzolilo) suggesting a third party, Billy (another prosecution witness), may have confessed to burning the car and destroying the murder weapon.
Goparian's requests to continue the trial to investigate this evidence, for postconviction discovery, and for an evidentiary hearing on these issues were denied by the trial judge.
On appeal, the central questions focused on whether the trial judge's denial of an evidentiary hearing and failure to address postconviction discovery constituted abuse of discretion given the potential exculpatory value of the evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Denial of evidentiary hearing on motion for new trial	Commonwealth argued no substantial issue raised	Goparian argued new evidence raised serious issue	Judge abused discretion; evidentiary hearing required for Nuzzolilo evidence
Failure to act on postconviction discovery request	Commonwealth asserted no new materials exist	Goparian argued prima facie need for discovery	Judge abused discretion; discovery should have been ordered
Obligation to disclose exculpatory evidence held by police	Disclosure not required for evidence in federal hands	Goparian argued state detective had knowledge	Prosecutor is obliged to disclose material known to local law enforcement investigators
Prejudice from nondisclosure of Nuzzolilo evidence	Statements not credible nor outcome-changing	Evidence might have influenced jury, supports third-party theory	Sufficient prejudice shown for hearing; evidence not merely cumulative or impeaching

Brady v. Maryland, 373 U.S. 83 (prosecution must disclose material exculpatory evidence to defendant)
Graham v. District Attorney for the Hampden Dist., 493 Mass. 348 (scope of prosecutorial disclosure obligations)
Commonwealth v. Scott, 470 Mass. 320 (right to present third-party culprit evidence)
Commonwealth v. Lykus, 451 Mass. 310 (prosecutor's duty to learn of and disclose exculpatory police-held evidence)
Commonwealth v. Stewart, 383 Mass. 253 (criteria for when evidentiary hearing on new trial motion is required)
Commonwealth v. Shakespeare, 493 Mass. 67 (substantive support versus impeachment value for third-party evidence)
Commonwealth v. Imbert, 479 Mass. 575 (standard for showing prejudice on nondisclosure when specific request was made)