Commonwealth v. Scott, 464 Mass. 355

Defendant convicted in Superior Court of multiple offenses including assault and battery causing serious bodily injury.
Victim sustained a liver laceration diagnosed as grade II, with hospital stay for observation after the October 2006 incident.
No medical expert testified about the content or meaning of the medical records.
Medical records showed liver laceration and free fluid but lacked explanation of severity or functional impact.
Commonwealth argued liver impairment satisfied the statute via impairment of an organ; defendant challenged sufficiency of evidence.
Court reversed on the conviction for assault and battery causing serious bodily injury and remanded for resentencing on remaining convictions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether liver impairment satisfies serious bodily injury under §13A(b)(i).	Commonwealth contends liver impairment satisfies impairment of an organ.	Duffly argues records insufficient to show impairment of liver.	No; impairment of an organ must be shown by meaningful evidence of functional impact.
Whether expert testimony is required to prove organ impairment under the statute.	Medical records alone can prove impairment.	Medical expertise is often required to interpret records.	Expert testimony is generally required when records are technical and not self-explanatory.
Whether the medical records’ Grade II liver laceration suffices to prove impairment.	Grade II indicates impairment.	Unexplained records cannot establish impairment beyond lay understanding.	Records alone do not establish impairment; jury could not determine severity.
Whether the jury could rely on circumstantial medical notes to find impairment.	Related symptoms support impairment.	Symptoms without explanation do not prove impairment.	Circumstantial notes insufficient without medical interpretation.
Whether the judgment should be reversed for insufficiency of proof and remanded.	Evidence supports conviction.	Evidence insufficient for impairment element.	Judgment reversed for the specific charge; remanded for resentencing on other convictions.

Commonwealth v. Brooks, 366 Mass. 423 (1974) (concepts of impairment and related terms construed in context of statute)
Commonwealth v. John T Connor Co., 222 Mass. 299 (1915) (statutory word scope analyzed with surrounding terms)
Commonwealth v. Jean-Pierre, 65 Mass. App. Ct. 162 (2005) (interpretation of impairment and disfigurement under §13A)
Commonwealth v. Kirkpatrick, 423 Mass. 436 (1996) (medical records without expert testimony may require exclusion)
Latimore, 378 Mass. 671 (1979) (capacity to prove essential elements beyond reasonable doubt)
Pitts v. Wingate at Brighton, Inc., 82 Mass. App. Ct. 285 (2012) (expert not always required in general knowledge contexts)
Baro, 73 Mass. App. Ct. 218 (2008) (serious bodily injury examples involving facial fractures)