Commonwealth v. Rivera, 121 N.E.3d 1121

Early morning altercation after convenience-store fight: defendant joined Soto in a fight during which Soto stabbed and later killed the victim; defendant rode with Soto and was dropped at his home shortly after.
Detectives interviewed the defendant a week later; he gave false or misleading statements about his whereabouts and his knowledge of Soto (referring to him as "Joel") and refused to provide Soto's phone number.
Soto was indicted and convicted of second-degree murder; defendant was indicted for accessory after the fact to murder and assault and battery; a jury convicted the defendant as an accessory after the fact and acquitted on assault and battery.
On appeal, the sole contested element addressed by the court was whether the defendant’s lies and refusal to provide a phone number constituted the requisite "aid" or "assistance" under G. L. c. 274, § 4.
The Supreme Judicial Court framed the issue against the common-law roots of accessory-after-the-fact liability and considered whether verbal conduct to police can amount to the direct, personal assistance required by the statute.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether lying to police and refusing to give a suspect's phone number can constitute "aid" or "assistance" under G. L. c. 274, § 4	Defendant’s lies and refusal obstructed investigation and therefore aided Soto in avoiding arrest/punishment	Mere false statements and refusal to cooperate, absent a false alibi, exculpatory narrative, or help in escape, do not satisfy the statutory "aid" or "assistance" element	Reversed: lies and refusal alone insufficient; conviction vacated

Commonwealth v. Perez, 437 Mass. 186 (construing accessory-after-the-fact statute against common-law roots)
Commonwealth v. Devlin, 366 Mass. 132 (discussing common-law origins and limits of accessory-after-the-fact liability)
Commonwealth v. Wood, 302 Mass. 265 (false statements providing exculpatory narrative/alibi supported accessory conviction)
Commonwealth v. Doherty, 353 Mass. 197 (coordinated false narrative and acts supporting accessory conviction)
Commonwealth v. Valleca, 358 Mass. 242 (aiding perpetrators to leave scene upheld accessory conviction)
Commonwealth v. Eagan, 357 Mass. 585 (aiding flight from crime scene supported accessory conviction)
Commonwealth v. Warren, 475 Mass. 530 (no obligation to answer police; protects silence/refusal)
Commonwealth v. Paquette, 475 Mass. 793 (willfully misleading police may be crime under separate statute when it materially alters investigation)