Commonwealth v. Joyner
467 Mass. 176
| Mass. | 2014Background
- Latent fingerprint from a masked intruder at a Brockton gas station linked to the defendant.
- Defendant was convicted of armed robbery under G. L. c. 265, § 17; probation was revoked as a result.
- Fingerprint expert relied on ACE-V methodology to compare latent print to defendant’s thumbprint; print had 21 minutiae points in common.
- Surveillance video and store witnesses supported that the defendant could not have touched the drawer except during the robbery.
- The defense challenged sufficiency of fingerprint proof, absence of force evidence, and closing argument misstatements; due process claims alleged during probation revocation.
- The trial court admitted fingerprint testimony without statistical population frequencies, focusing on expert opinion rather than absolute certainty.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of fingerprint identification | Commonwealth | Duffly | Evidence sufficient to identify the defendant |
| Force element for armed robbery | Commonwealth | Duffly | Sufficient fear/force shown by weapon and threat |
| Closing argument misstatement | Commonwealth | Duffly | No error; arguments supported by evidence |
| Probation revocation due process | Commonwealth | Duffly | Due process not violated; evidence properly limited to stages |
Key Cases Cited
- Commonwealth v. Gambora, 457 Mass. 715 (Mass. 2010) (fingerprint testimony admissible as opinion under ACE-V; caution on certainty)
- Commonwealth v. Patterson, 445 Mass. 626 (Mass. 2005) (ACE-V methodology reliability; discussion of expert testimony scope)
- Commonwealth v. Beausoleil, 397 Mass. 206 (Mass. 1986) (absence of statistical data does not bar identification testimony)
- Commonwealth v. Drayton, 386 Mass. 39 (Mass. 1982) (statistical population data not required for fingerprint identification)
- Commonwealth v. Grandison, 433 Mass. 135 (Mass. 2001) (standard for reviewing prosecutorial closing argument; substantial miscarriages)
- Commonwealth v. Kelsey, 464 Mass. 315 (Mass. 2013) (due process in probation revocation hearings; right to defense evidence)
- Commonwealth v. LaCorte, 373 Mass. 700 (Mass. 1977) (jury credibility and weighing expert testimony is for the jury)