Commonwealth v. Hernandez
27 N.E.3d 380
Mass.2015Background
- Defendant Aaron Hernandez was on trial in Superior Court for first‑degree murder and related firearms offenses; the Commonwealth moved in limine to admit testimony from witness Robert Paradis.
- Paradis’s voir dire proffered that roughly six weeks before the murder he heard Hernandez reference having “heat” or a ".45" under his seat while in California, and that Paradis later felt a firearm wrapped inside a black T‑shirt in Hernandez’s dresser drawer.
- The trial judge denied the Commonwealth’s motion in limine, excluding Paradis’s testimony as more prejudicial than probative because there was no evidence the weapon he felt was the murder weapon or that Hernandez had access to it in Massachusetts at the time of the killing.
- The Commonwealth sought review under the Supreme Judicial Court’s extraordinary general‑superintendence power, G. L. c. 211, § 3; a single justice denied relief and the Commonwealth appealed to the full court.
- The SJC reviewed whether § 3 relief was appropriate and whether the trial judge abused her discretion in excluding the evidence; the court affirmed the single justice, finding no error and that the situation did not warrant extraordinary relief.
Issues
| Issue | Plaintiff's Argument (Commonwealth) | Defendant's Argument (Hernandez) | Held |
|---|---|---|---|
| Appropriateness of G. L. c. 211, § 3 review | Relief under § 3 necessary because no other appellate remedy exists for interlocutory evidentiary rulings | § 3 is extraordinary and should not be used to review routine evidentiary rulings; trial court is best forum | Denied — § 3 is not automatic; relief is for exceptional, irremediable errors and not routine evidentiary rulings |
| Admissibility — relevance and materiality of Paradis’s testimony | Testimony shows Hernandez had a .45 and a firearm in his possession shortly before the murder; probative of access to the weapon | Testimony is too attenuated — no evidence the firearm was the murder weapon or that Hernandez had it in Massachusetts at time of offense; prejudicial | Denied — trial judge did not err in finding prejudicial effect outweighed probative value given lack of link to murder weapon or access in MA |
| Burden to create the record for § 3 review | Commonwealth proceeded on the existing record and video of parts of the hearing | The petitioner must supply the full trial‑court record for meaningful review | Court noted Commonwealth failed to include motion/opposition and written transcript; petitioner bears burden to create complete record |
| Standard of review for evidentiary rulings | Argued judge misapplied balancing and relevance standards | Judge’s discretionary ruling should stand absent palpable error | Held — decision was within judge’s broad discretion and not palpably erroneous |
Key Cases Cited
- Commonwealth v. Snow, 456 Mass. 1019 (2010) (§ 3 review is not automatic simply because no other remedy exists)
- Commonwealth v. Richardson, 454 Mass. 1005 (2009) (extraordinary relief under § 3 is sparingly used)
- Commonwealth v. Cook, 380 Mass. 314 (1980) (§ 3 relief reserved for extraordinary circumstances)
- Commonwealth v. Yelle, 390 Mass. 678 (1983) (courts refuse to use § 3 to second‑guess routine evidentiary rulings)
- Commonwealth v. Sylvia, 456 Mass. 182 (2010) (evidentiary rulings reviewed for palpable error and abuse of discretion)
- Commonwealth v. Simpson, 434 Mass. 570 (2001) (trial judge’s broad discretion on admissibility matters)
- Gorod v. Tabachnick, 428 Mass. 1001 (1998) (petitioner’s burden to create a complete record for § 3 proceedings)
- Planned Parenthood League of Mass. v. Operation Rescue, 406 Mass. 701 (1990) (procedural note on § 3 review standards)
- Commonwealth v. Dunigan, 384 Mass. 1 (1981) (same standard of review whether single justice or full court reviews § 3 petitions)