Commonwealth v. Robinson, 493 Mass. 303

Jason Robinson was convicted of first-degree felony murder, with armed robbery as the predicate offense, in connection with the shooting death of Inaam Yazbek.
The murder followed a planned robbery involving Robinson, codefendant Tanzerius Anderson, and another accomplice, Joleena Tate, wherein the victim was lured to an apartment building.
During the robbery, Anderson shot Yazbek while Robinson participated by aiding in the robbery and handling stolen property after the fact.
Robinson's conviction was appealed, with claims of insufficient evidence, evidentiary errors, improper jury instructions, and sentencing challenges.
The Massachusetts Supreme Judicial Court affirmed the conviction but found the sentence of life without parole unconstitutional for a nineteen-year-old under the recent Mattis decision, remanding for resentencing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for felony-murder	Evidence was sufficient to infer joint venture and armed robbery	Insufficient evidence Robinson knew Anderson was armed	Evidence was sufficient for conviction
Admission of codefendant's statements	Anderson’s statements admissible under joint venture and hearsay	Statements were prejudicial hearsay/Bruton violation	Properly admitted under joint venture and no Bruton error
Denial of severance/joint trial	No antagonistic defenses, no prejudice to Robinson	Prejudicial spillover from evidence against Anderson	No abuse of discretion in denying severance
Jury instructions on individual consideration	Instructions were adequate and given as required	Jury should have been instructed more clearly on separation	Instructions were proper; no miscarriage of justice
Exclusion of third-party culprit evidence	Evidence too speculative and not sufficiently connected	Judge erred by excluding possible alternative culprits	No error; evidence lacked substantial links to the crime
Constitutionality of life without parole @ 19	Sentence is unconstitutional for under 21 per Mattis	Sentence should be affirmed	Sentence vacated; remand for resentencing under Mattis

Commonwealth v. Gallett, 481 Mass. 662 (defining joint venture felony-murder requirements)
Commonwealth v. Phap Buth, 480 Mass. 113 (knowledge of coventurer’s weapon may be inferred)
Commonwealth v. Rakes, 478 Mass. 22 (joint venturer’s statements in concealment phase admissible)
Commonwealth v. Winquist, 474 Mass. 517 (admissibility of post-crime joint venture statements)
Commonwealth v. Sylvia, 456 Mass. 182 (jury presumed to follow limiting instructions)
Commonwealth v. Siny Van Tran, 460 Mass. 535 (standards for severance in joint criminal trials)
Commonwealth v. Ciampa, 406 Mass. 257 (guidance on plea-bargain witness credibility instructions)
Commonwealth v. Bowden, 379 Mass. 472 (defense may question adequacy of police investigation)
Commonwealth v. Mattis, 493 Mass.(2023) (life without parole unconstitutional for those under 21 at offense)