Commonwealth v. Griffin
475 Mass. 848
| Mass. | 2016Background
- In July 2009 the defendant broke into his former girlfriend Mons's home and fatally cut the throat of his six‑year‑old daughter; he was arrested after admitting the killing and leaving notes expressing remorse and purportedly religious justification.
- Defendant conceded the act but pleaded not criminally responsible (insanity); no expert psychiatric testimony was presented by either side at trial.
- Evidence at trial showed planning and steps to avoid detection (packed supplies, walked in rain to avoid noise, cut phone lines, turned off electricity, cleaned up, repacked backpack), prior statements about suicide, prior hospitalizations and disability benefits for mood disorder, and mixed indications about religiosity.
- A jury convicted the defendant of first‑degree murder (premeditation and extreme atrocity) and home invasion; he received life without parole for murder; he appealed raising four claims.
- The defendant appealed: (1) sufficiency of evidence to prove criminal responsibility beyond a reasonable doubt; (2) ineffective assistance for defense counsel’s statement in opening that the conduct was "not psychotic"; (3) prosecutorial improprieties in opening/closing; (4) jury instruction regarding consequences of a not guilty by reason of lack of criminal responsibility (Mutina instruction) and an instruction about the general inference that people are sane.
Issues
| Issue | Plaintiff's Argument (Commonwealth) | Defendant's Argument (Griffin) | Held |
|---|---|---|---|
| Sufficiency of evidence on criminal responsibility | Evidence of planning, motive, efforts to avoid detection and post‑offense conduct show capacity to appreciate wrongfulness and conform conduct | Defendant says evidence was insufficient; his statements to police showed he was acting under delusional command from God | Conviction affirmed: circumstantial evidence (planning, motive, concealment, inconsistent self‑reports) permitted rational jury to find criminal responsibility beyond a reasonable doubt (no expert required) |
| Ineffective assistance for conceding "not psychotic" in opening | N/A | Counsel’s remark undermined insanity defense and was manifestly unreasonable | Rejected: statement was a strategic attempt to explain how defendant could act deliberately yet lack capacity; not manifestly unreasonable on record |
| Prosecutorial statements in opening/closing | Prosecutor may argue credibility and inferences from evidence (planning, inconsistencies) | Prosecutors improperly called killing "murder" in opening and vouched that defendant wasn’t mentally ill in argument | Most objections rejected: prosecutor’s use of "murder" was improper but cured by judge’s prompt curative instruction; argument about lack of mental disease was permissible non‑expert inference and about defendant’s statements being self‑serving was proper impeachment |
| Jury instruction on consequences of NGRI (Mutina) and sane‑person inference | Model/Mutina instruction accurately states law; judge may also note that most people are sane if appropriate | Instruction created risk jurors would think NGRI leads to instant release; inclusion of sane‑person inference (per Keita) is problematic per Lawson | Held: Model/Mutina instruction proper and not a miscarriage of justice; the judge’s additional sane‑person remark did not prejudice given strong burden instruction and substantial evidence of responsibility |
Key Cases Cited
- Commonwealth v. Lawson, 475 Mass. 806 (Mass. 2016) (explains limits of sane‑person inference and standard for proving criminal responsibility without expert testimony)
- Commonwealth v. Keita, 429 Mass. 843 (Mass. 1999) (instructing jury that majority of people are sane may be appropriate)
- Commonwealth v. Cullen, 395 Mass. 225 (Mass. 1985) (planning and conduct may prove criminal responsibility)
- Commonwealth v. Ricard, 355 Mass. 509 (Mass. 1969) (criminal responsibility may be proved without expert testimony)
- Commonwealth v. Kostka, 370 Mass. 516 (Mass. 1976) (planning and motive support criminal responsibility)
- Commonwealth v. Chappell, 473 Mass. 191 (Mass. 2015) (approves model Mutina instruction and discusses potential modifications)
- Commonwealth v. Mutina, 366 Mass. 810 (Mass. 1975) (original case discussing consequences of NGRI verdict)
- Commonwealth v. Lyons, 426 Mass. 466 (Mass. 1998) (prosecutor may argue credibility of insanity defense based on record evidence)
- Commonwealth v. Almonte, 465 Mass. 224 (Mass. 2013) (curative instruction can cure improper prosecutorial characterization in opening)
- Commonwealth v. Denis, 442 Mass. 617 (Mass. 2004) (strategic concessions can be reasonable when consistent with viable defense)