Commonwealth v. Prunty, 462 Mass. 295

Defendant Daniel J. Prunty was convicted of first-degree murder by deliberate premeditation, plus assault with a dangerous weapon and attempted extortion, arising from a home shooting of Jason Wells on Aug. 7, 2004.
The State’s case included a contemporaneous party, discovery of missing items, and a confrontation between Wells and Prunty over stolen property.
During jury empanelment, the defense challenged Juror No. 16, the venire’s only African-American member, on grounds of racial prejudice and related rationale.
The judge conducted individualized voir dire and ultimately seated Juror No. 16 over defense objection, with the juror later serving as foreperson.
The defense argued the trial court erred in admitting and limiting use of Pape’s prior inconsistent statements; the court instructed the jury that such statements could only affect credibility, not the truth.
On appeal, Prunty challenged the peremptory challenge and the limiting instruction; the court affirmed the convictions and declined to grant new trial or reduce the verdict.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was Juror No. 16 improperly excluded or retained under peremptory challenge rules?	Prunty asserts improper use of peremptory to remove African-American juror.	Prunty contends race-based bias invalidated the challenge.	No reversible error; Juror No. 16 properly seated, with legitimate analysis and Harris framework applied.
Did the trial court err in limiting use of prior inconsistent statements from Pape?	Limited instruction should not have curtailed substantive use of prior statements.	Limitation was error that could affect justice.	Assuming error, no substantial risk of miscarriage; overwhelming evidence supports conviction.
Did the jury-selection and limiting-instruction decisions render the trial fair under Batson/Soares framework?	Commonwealth argues proper application of Batson/Soares, including single-juror challenge.	Defendant argues improper discrimination and lack of genuine, race-neutral justification.	Court applied correct standard; no abuse of discretion; verdict affirmed.

Commonwealth v. Young, 401 Mass. 390 (1987) (voir dire for racial prejudice when requested by defendant)
Commonwealth v. Ramirez, 407 Mass. 553 (1990) (limits on voir dire and use of racial considerations)
Commonwealth v. Vann Long, 419 Mass. 798 (1995) (Batson/Soares framework; equal protection in peremptory challenges)
Commonwealth v. Soares, 377 Mass. 461 (1979) (prohibition on excluding jurors by group membership; cross-section requirement)
Commonwealth v. Harris, 409 Mass. 461 (1991) (single-member proxy for group discrimination; Harris exception)
Commonwealth v. Curtiss, 424 Mass. 78 (1997) (application of Harris exception to defendant's challenge; Bona fide/genuine reasons)
Commonwealth v. Maldonado, 439 Mass. 460 (2003) (adequacy and genuineness of race-neutral explanations)
Commonwealth v. Garrey, 436 Mass. 422 (2002) (occupational bias scrutiny in peremptory challenges)
Commonwealth v. Benoit, 452 Mass. 212 (2008) (occupational basis for peremptory challenges; scrutiny of rationale)
Batson v. Kentucky, 476 U.S. 79 (1986) (prohibition on racial discrimination in peremptory challenges)