Commonwealth v. Goddard
476 Mass. 443
| Mass. | 2017Background
- Defendant William Goddard fatally shot his ex-girlfriend at her workplace on January 28, 2008, also wounding her boss and firing at other employees; he fled the scene and was later arrested after a standoff.
- After the shooting, the defendant made phone calls (including to an ATF agent) admitting he may have shot people and stated he would rather kill himself than turn himself in; a CD found in his truck contained a recorded statement expressing intent and admitting he decided to kill the victim.
- Forensic evidence from the defendant’s computer showed Internet searches such as "How to kill someone" and "Murder an ex-girlfriend" in the months before the killing.
- At trial the defendant conceded the killing but raised lack of criminal responsibility (insanity) as his defense; defense expert Dr. Brown testified the defendant had bipolar disorder, PTSD, and possibly a seizure disorder impairing his capacity to conform conduct to law.
- Commonwealth rebuttal expert Dr. Alison Fife testified the defendant did not suffer a mental disease impairing his capacity and opined the defendant’s behaviors that day were planned/goal-directed; the jury convicted Goddard of first-degree murder (deliberate premeditation) among other offenses.
Issues
| Issue | Commonwealth's Argument | Goddard's Argument | Held |
|---|---|---|---|
| Whether Commonwealth expert could testify an opinion touching premeditation/ultimate issue | Expert may offer opinion on matters related to ultimate issue (e.g., goal-directed behavior) relevant to criminal responsibility | Such testimony impermissibly touches the ultimate issue of guilt/premeditation and usurps jury function | Permitted: expert may give opinion on goal-directed/planned behavior relevant to criminal responsibility; no reversible error given overwhelming evidence of premeditation |
| Whether Dr. Fife could state bases for her opinion on direct examination | Expert may reference facts already in evidence and permissible bases; her references largely relied on admitted evidence | Permitted testimony improperly introduced facts not in evidence on direct examination | Permitted: virtually all bases cited were in the record; one fleeting, inadmissible middle-school anecdote was harmless |
| Whether prosecutor misstated evidence in closing by asserting CD was made in January 2008 | Argued timing of CD in January was a reasonable inference from CD language and other evidence | Argued prosecutor misstated evidence by asserting the CD date without conclusive proof | No error: jury could reasonably infer the CD was made in January; prosecutor’s statements were permissible argument/inferences |
| Whether record warrants relief under G. L. c. 278, § 33E (interest of justice review) | No miscarriage of justice; convictions supported by record | Sought reversal or lesser verdict/new trial | Denied: convictions affirmed and no relief under § 33E |
Key Cases Cited
- Commonwealth v. Canty, 466 Mass. 535 (expert may give opinions touching ultimate issue; weigh probative value vs. prejudice)
- Commonwealth v. Hamilton, 459 Mass. 422 (expert cannot state defendant is guilty or innocent)
- Commonwealth v. Markvart, 437 Mass. 331 (permissible bases for expert opinion; limitations on direct testimony about facts not in evidence)
- Commonwealth v. Barbosa, 457 Mass. 773 (expert may not inform jury on direct about facts not in evidence; foundation and cross-examination limits)
- Commonwealth v. Boateng, 438 Mass. 498 (expert testimony about goal-directed actions permissible in criminal responsibility context)