Commonwealth v. Miller
475 Mass. 212
| Mass. | 2016Background
- Miller was indicted for first-degree murder and related firearm offenses after the September 25, 2006 killing in Fall River; trial began in 2009 with Miller proceeding pro se but standby counsel participating.
- Jury returned guilty verdicts on murder in the first degree on a theory of deliberate premeditation and unlawful possession of a firearm.
- A juror wrote to the judge expressing concerns about extraneous material reaching the jury; Miller moved for a new trial based on that letter.
- A prison mail interception led Miller to move to suppress a letter and attached grand jury transcript; suppression hearing conduct contested, but ruling addressed waived issues.
- Evidence at trial included a rifle linked to the defendant, shell casings matching the murder, and a basement-seized rifle case and magazines; grand jury transcript and letter were admitted in evidence under a stipulation.
- The defendant challenged suppression rulings, the new-trial motion, and the admission of certain evidence; the Appeals Court affirmed the convictions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the basement evidence was within the search warrant scope | Miller, automatic standing over third indictment | Items seized from neighbor’s unit outside scope | Automatic standing limited; third indictment valid for challenge |
| Whether the prison letter and grand jury transcript were improperly suppressed due to failure to appear | Waiver improper; suppression warranted | Waiver valid; suppression unnecessary | Waiver error but no substantial miscarriage of justice |
| Whether extraneous BB gun material in deliberations deprived Miller of a fair trial | Extraneous material prejudicial | No prejudice given strong evidence of guilt | No abuse of discretion; not prejudicial |
| Whether admission of the grand jury transcript and attached letter was reversible error | Statements are hearsay and prejudice | Stipulation made admission valid | Stipulation valid; admission not reversible error |
| Whether immunized witness testimony improperly bolstered credibility | Prosecutor cannot bolster immunized witness | No improper bolstering given defenses raised otherwise | No error; immunized witness instruction provided |
| Whether evidence issues (chain of custody, domestic-violence testimony) affected verdict | Chain-of-custody weaknesses affect admissibility/weight | Evidence had sufficient corroboration; weight not error | Weight and credibility resolved by judge; no reversible error |
Key Cases Cited
- Commonwealth v. Amendola, 406 Mass. 592 (Mass. 1990) (art. 14 automatic standing where possession is element of offense)
- United States v. Salvucci, 448 U.S. 83 (U.S. 1980) (abandoned automatic standing; state law governs?)
- Commonwealth v. Frazier, 410 Mass. 235 (Mass. 1991) (standing to challenge search when possession is element; conspiracy not)
- Commonwealth v. Kincaid, 444 Mass. 381 (Mass. 2005) (Fidler framework; juror deliberations limitations clarified)
- Commonwealth v. Fidler, 377 Mass. 192 (Mass. 1979) (extraneous material during deliberations; required hearing)
- Commonwealth v. Scanlon, 412 Mass. 664 (Mass. 1992) (consciousness-of-guilt doctrine; hearsay disclosures)
- Commonwealth v. Cuffie, 414 Mass. 632 (Mass. 1993) (limits on juror deliberation evidence (overruled on other grounds))
- Commonwealth v. Scanlon, 412 Mass. 664 (Mass. 1992) (consciousness of guilt evidence admissibility)