Commonwealth v. Oberle
476 Mass. 539
| Mass. | 2017Background
- Victim and defendant were in an intimate relationship with prior domestic violence; in Feb 2014 defendant beat and strangled the victim and threatened to kill her. Photographs of those injuries existed.
- The couple later lived in a basement bedroom with a private back door; on July 4–5, 2014 the defendant assaulted, choked, and allegedly held the victim until she lost consciousness; she later escaped barefoot and injured and called 911. Medical evidence was consistent with strangulation and multiple blows.
- Defendant was indicted on attempted murder, kidnapping, witness intimidation, and four assault and battery counts; the jury convicted him of kidnapping and three counts of assault and battery and acquitted him of attempted murder and one A&B count.
- At voir dire the defense exercised multiple peremptory challenges to female prospective jurors; the judge found a pattern of excluding women and denied one peremptory challenge to juror no. 15 (a mandated reporter/teacher), seating her over objection.
- The Commonwealth introduced prior-bad-act evidence (Feb. 2014 beating) and enlarged photographs; the judge gave limiting instructions that the prior incident could be considered only on relationship, intent, motive, absence of mistake/accident.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Denial of peremptory challenge to juror no. 15 | Court should uphold judge's discretion to police discriminatory patterns | Oberle argued the judge wrongly denied a peremptory strike based on gender and that denial was structural error requiring reversal | Denial affirmed: judge did not abuse discretion; he found a pattern of excluding women and concluded defense proffer was pretextual (genuineness lacking) |
| Adequacy of judge's findings on peremptory challenge | N/A (Commonwealth relied on judge's discretion and record) | Oberle argued lack of detailed separate findings on adequacy and genuineness required reversal | Court emphasized judges should make separate findings but concluded record sufficiently supports denial on genuineness ground; affirmed |
| Sufficiency of evidence for kidnapping (G. L. c. 265, § 26) | Commonwealth: confinement/restraint independent of assaults shown by choking, inability to call for help, loss of consciousness, protracted restraint until daylight | Oberle: confinement was incidental to assaults, not independent conduct supporting kidnapping | Conviction affirmed: evidence of forcible/protracted restraint independent of A&B was sufficient to support kidnapping |
| Admissibility of prior bad-act evidence and enlarged photos (Feb. 2014) | Commonwealth: prior beating probative of relationship, intent, motive, and relevant to attempted murder charge | Oberle: prior-act evidence and poster-size photos were unfairly prejudicial and inflammatory | Admission affirmed: prior domestic-violence acts were properly admitted for intent/relationship; probative value outweighed prejudice; judge’s limiting instructions and discretion over photographs upheld (court questioned poster-size enlargements but found no abuse) |
Key Cases Cited
- Commonwealth v. Rodriguez, 431 Mass. 804 (discusses limits on gender-based peremptory strikes)
- Commonwealth v. Soares, 377 Mass. 461 (peremptory challenges and discrete group protection)
- Commonwealth v. Maldonado, 439 Mass. 460 (framework: pattern, then adequacy and genuineness of explanation)
- Commonwealth v. Hampton, 457 Mass. 152 (erroneous denial of peremptory challenge is structural error)
- Commonwealth v. Dykens, 438 Mass. 827 (definition of confinement for kidnapping is broadly interpreted)
- Commonwealth v. Boyd, 73 Mass. App. Ct. 190 (confinement must be independent of other crimes to support kidnapping)
- Commonwealth v. Crayton, 470 Mass. 228 (balancing probative value and prejudice for prior-bad-act evidence)
- Commonwealth v. Bell, 473 Mass. 131 (photographs admissible if relevant; gruesomeness alone not dispositive)