Commonwealth v. Lacoy
90 Mass. App. Ct. 427
| Mass. App. Ct. | 2016Background
- Defendant John Lacoy stabbed Casey Taylor, who later died of a single stab wound to the heart; Taylor's decomposing body was found under the defendant's back stairs nine days later.
- Lacoy and Taylor were alcoholics who lived together intermittently; Lacoy admitted drugging and sexually assaulting Taylor on prior occasions and had threatened him.
- Lacoy gave varying accounts of the death (self-defense, accident, unknown disappearance) and sent messages expressing relief that Taylor was gone; recorded statements and emails were introduced at trial.
- Lacoy was convicted by a jury of second-degree murder; at trial the defense argued self-defense or accident, while the Commonwealth emphasized motive, prior sexual assaults, and concealment.
- On appeal Lacoy raised claims concerning discriminatory peremptory challenges (race/sexual orientation), ineffective assistance of counsel (defense counsel’s repeated emphasis on homosexuality), admission of prior-bad-acts evidence (sexual assaults), and the trial court’s refusal to instruct on sudden combat and involuntary manslaughter.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Peremptory challenges (juror 165 — African‑American female) | Commonwealth: challenge was for a nonracial, job‑related reason (hospital employment) | Lacoy: challenge showed racial pattern; judge erred and failed to apply Soares/Batson properly | Court upheld excusal; even if close, defendant waived appellate review by not objecting and failed to show miscarriage of justice |
| Peremptory challenges (juror 179 — gay African‑American male) | Commonwealth: challenge based on juror’s inaccurate disclosures and probative unreliability | Lacoy: proffered reason was pretextual; challenge discriminated by sexual orientation and race | Court found proffer genuine and specific to omissions; excusal permissible; assumed Soares could extend to sexual orientation but no error shown |
| Ineffective assistance of counsel | Lacoy: defense counsel’s repeated, stereotyped emphasis on homosexuality was manifestly unreasonable and prejudicial | Commonwealth: tactic to blunt Commonwealth’s expected focus on sexual conduct; counsel contested and presented defense | Court: tactical choice (though some rhetoric was objectionable) not shown to be so deficient as to create reasonable doubt given overwhelming evidence; no relief |
| Admission of prior bad acts (sexual assaults) | Lacoy: evidence was propensity evidence and unduly prejudicial | Commonwealth: evidence was admissible to show relationship, motive, intent, and to rebut accident/self‑defense | Court: evidence relevant to motive and intent; judge did not abuse discretion and gave limiting instructions |
| Jury instructions (sudden combat and involuntary manslaughter) | Lacoy: judge should have instructed on sudden combat and involuntary manslaughter theories | Commonwealth: record did not support those instructions given testimony (defendant’s inconsistent account; claimed accident/self‑defense) | Court: refusal proper—evidence did not support sudden combat; defendant’s testimony did not show the wanton/reckless conduct required for involuntary manslaughter |
Key Cases Cited
- Commonwealth v. Issa, 466 Mass. 1 (discussing Batson/Soares principles in Massachusetts)
- Commonwealth v. Soares, 377 Mass. 461 (establishing Massachusetts approach to race‑based peremptory challenges)
- Batson v. Kentucky, 476 U.S. 79 (prohibiting race‑based peremptory challenges)
- Powers v. Ohio, 499 U.S. 400 (defendant may object to race‑based strikes of jurors of a different race)
- Miller‑El v. Dretke, 545 U.S. 231 (defendant entitled to jury selection free of racial bias)
- Commonwealth v. Benoit, 452 Mass. 212 (prima facie showing and burden shifts in peremptory challenge review)
- Commonwealth v. Rodriguez, 457 Mass. 461 (requirement for discernible findings during Batson/Soares inquiry)
- Commonwealth v. Maldonado, 439 Mass. 460 (discussion of judge’s findings in peremptory challenge context)
- Commonwealth v. Burnett, 418 Mass. 769 (need for clear, specific, group‑neutral reasons)
- Commonwealth v. Crayton, 470 Mass. 228 (limits on other‑bad‑acts evidence; admissibility for motive/intent)
- Commonwealth v. Walker, 460 Mass. 590 (probative value vs. unfair prejudice for prior acts)
- Commonwealth v. Kolenovic, 471 Mass. 664 (standards for ineffective assistance when claim rests on strategy)
- Commonwealth v. Saferian, 366 Mass. 89 (standard for ineffective assistance claims)
- Commonwealth v. Millien, 474 Mass. 417 (review standard for jury‑selection error and substantial risk of miscarriage of justice)
- Cronic v. United States, 466 U.S. 648 (circumstances requiring no showing of prejudice for deprivation of counsel)