Commonwealth v. Piantedosi
SJC 11802
| Mass. | Dec 18, 2017Background
- Defendant Christopher Piantedosi stabbed his longtime girlfriend to death on May 3, 2012; he conceded the killing but pleaded not criminally responsible due to involuntary intoxication from prescribed antidepressants and underlying bipolar disorder.
- The murder occurred in front of the couple’s teenage daughter; another teen observed parts of the attack via a live video chat. Victim sustained more than thirty stab wounds. Defendant fled and was arrested the next day.
- Defense presented forensic psychiatrist Dr. Wade Meyers and medical records to support a theory that Prozac and trazodone triggered a manic/irritable state (involuntary intoxication) and that defendant lacked capacity to appreciate wrongfulness or conform conduct.
- Commonwealth rebutted with forensic psychiatrist Dr. Alison Fife who rejected the intoxication/bipolar diagnosis and testified that anger, sadness, and rage—rather than mental disease—drove the conduct.
- At trial the judge excluded on direct examination certain hearsay statements the defense expert had obtained from the defendant (per Mass. G. Evid. § 703/Department of Youth Servs. rule), allowed the Commonwealth expert to testify about what “drove” the defendant, and gave the then-governing Mutina instruction about consequences of an insanity verdict.
- On appeal the defendant challenged exclusion of his out-of-court statements through his expert, admission of the Commonwealth expert’s testimony about motive and phrasing of the McHoul standard, and the Mutina instruction; defendant also sought relief under G. L. c. 278, § 33E. Court affirmed convictions and denied § 33E relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Exclusion of defendant’s statements on direct through defense expert | Commonwealth: limit direct expert testimony to avoid importing hearsay; follow Department of Youth Servs./§ 703 approach | Piantedosi: exclusion deprived him of full defense and violated Due Process and Sixth Amendment | Held: No error — expert may rely on otherwise admissible out-of-court data but may not relate substance on direct; opposing party can probe on cross and court allowed limited follow-up on redirect |
| Commonwealth expert testifying about what “drove” the killing | Commonwealth: expert may explain motive and medical/psychological basis for behavior; need not recite McHoul formula verbatim | Piantedosi: testimony misstated McHoul and usurped jury’s role on ultimate issue | Held: No reversible error — expert may state medical/psychological causes and approach ultimate issue; judge corrected law in instructions and jury received correct McHoul charge |
| Expert’s misstatement of McHoul standard | Commonwealth: minor and cured by judge’s instruction | Piantedosi: misstatement likely to confuse jury and prejudice defendant | Held: Harmless — judge interrupted, instructed jury that she would give law, and final charge correctly stated McHoul standard |
| Mutina instruction on consequences of NGRI verdict | Commonwealth: the then-current Mutina instruction correctly stated law | Piantedosi: jury should have been told explicitly that commitment could potentially be for life | Held: No error — instruction matched governing model at trial date; not substantially likely to cause miscarriage of justice |
Key Cases Cited
- Department of Youth Servs. v. A Juvenile, 398 Mass. 516 (1986) (permits expert to base opinion on facts not in evidence if independently admissible, but bars direct testimony to substance of those facts)
- Commonwealth v. Barbosa, 457 Mass. 773 (2010) (expert opinion must be based on permissible sources; discussion of limits on expert hearsay testimony)
- Commonwealth v. Chappell, 473 Mass. 191 (2015) (clarifies expert testimony limits under Dept. of Youth Servs. and Mutina instruction modifications)
- Commonwealth v. Goddard, 476 Mass. 443 (2017) (prevents importation of inadmissible hearsay via expert and allows expert testimony on planning/goal-directed behavior)
- Commonwealth v. Nardi, 452 Mass. 379 (2008) (expert may not state hearsay bases of opinion on direct examination)
- Commonwealth v. Johnston, 467 Mass. 674 (2014) (expert testimony implying motive rather than mental illness can be admissible; cautions against summarizing witness statements on direct)
- Commonwealth v. McHoul, 352 Mass. 544 (1967) (formulation of legal standard for criminal responsibility/insanity)
- Commonwealth v. Shelley, 381 Mass. 340 (1980) (expert should be asked to cast opinion in legal terms if referencing legal standards)
- Commonwealth v. Mutina, 366 Mass. 810 (1974) (consequences and commitment procedures following verdict of not guilty by reason of insanity)
- Commonwealth v. LaFave, 407 Mass. 927 (1990) (expert allowed to testify concerning motive)
- Commonwealth v. Lodge, 431 Mass. 461 (2000) (expert may not testify to guilt/innocence but may approach ultimate issues)
- Commonwealth v. Okoro, 471 Mass. 51 (2015) (expert opinions that approach ultimate issues are not per se improper)