Commonwealth v. Mejia
461 Mass. 384
Mass.2012Background
- Dec. 12, 2007: decomposed bodies of a mother and her two daughters found in Springfield; defendant (stepfather) resided with them.
- Victims bound with rope; no signs of forced entry; mother had multiple stab wounds, throat slit, blunt force trauma.
- Older daughter (9) manually strangled; younger daughter (6) asphyxiated with tights; sign of attempts to conceal and clean scene.
- DNA linked defendant to ropes on older daughter and neck bruises; no usable fingerprints found; no robbery evident.
- Defendant exhibited erratic behavior in community prior to discovery; later hospitalized after contact with police, where his demeanor became a focal point of trial.
- Significant evidentiary issues: unaired unsigned Spanish note found; note exposure to jurors during deliberations; court conducted voir dire of jurors and avoided mistrial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of behavior at hospital | Commonwealth contends demeanor evidence reflects knowledge of crimes and guilt. | Ireland argues custodial interrogation without Miranda warnings; demeanor improperly admitted. | No custodial interrogation; demeanor properly admitted. |
| denial of motion for required findings of not guilty | Commonwealth asserts sufficient evidence of guilt beyond reasonable doubt. | Ireland argues scant direct evidence; case rests on demeanor and DNA not tying directly to him. | Evidence sufficient to support jury verdict. |
| Handwritten Spanish note and mistrial | Note contained defendant's admission; translation issue could prejudice jurors. | Note prejudices jury and violated constitutional rights; mistrial warranted. | No mistrial; voir direing jurors controlled potential prejudice. |
| Reduction under G. L. c. 278, § 33E | No grounds to reduce to second-degree murder; no substantial mental impairment shown. | Potential psychosis/mental impairment argued; justice requires reduction. | Denial of reduction; no manifest mental impairment to warrant reduction. |
Key Cases Cited
- Commonwealth v. Morse, 427 Mass. 117 (Mass. 1998) (custodial interrogation requires Miranda warnings; test for custodial interrogation)
- Commonwealth v. Jung, 420 Mass. 675 (Mass. 1995) (Miranda/Warnings analysis for custodial interrogation)
- Commonwealth v. Kirwan, 448 Mass. 304 (Mass. 2007) (defendant bears burden to prove custodial interrogation)
- Commonwealth v. Groome, 435 Mass. 201 (Mass. 2001) (criteria for determining custodial interrogation factors)
- Commonwealth v. Womack, 457 Mass. 268 (Mass. 2010) (discretion in handling extraneous material during trial and mistrial)
- Commonwealth v. Francis, 432 Mass. 353 (Mass. 2000) (voir dire when juror exposure to extraneous material occurs)
- Commonwealth v. Jackson, 376 Mass. 790 (Mass. 1978) (juror exposure; voir dire requirement outside presence of others)
- Commonwealth v. Kincaid, 444 Mass. 381 (Mass. 2005) (post-verdict inquiries into jury exposure to extraneous information)
- Commonwealth v. Fidler, 377 Mass. 192 (Mass. 1979) (pretrial/posttrial review of juror exposure to extraneous material)
- Commonwealth v. Lao, 443 Mass. 770 (Mass. 2005) (evidence standards for circumstantial cases and reasonable inferences)