Commonwealth v. Snyder
57 N.E.3d 976
Mass.2016Background
- In 1994 Joseph O’Reilly was shot dead outside his girlfriend’s Quincy apartment; neighbors saw two white men flee and others saw two men near the nearby bridge earlier that evening.
- Longstanding animus: Snyder had a contentious history with O’Reilly (threats, parole revocation, harassment of Snyder’s partner and family), supporting motive for the Commonwealth.
- Key evidence: (1) William Petras identified Snyder from a 50-photo array the day after the shooting; (2) Arnold Emma testified Snyder confessed in jail and described planning and wearing ski masks; (3) Carol O’Mahony made an in-court identification years later; and (4) an orange stocking cap with eye-holes was found months later in a car Snyder had driven.
- Pretrial: Snyder sought funds and a Daubert hearing to admit expert eyewitness-identification testimony (Dr. Steven Penrod); the trial judge denied both the evidentiary hearing and admission of the expert.
- Trial/result: Snyder’s defense was mistaken identity and an alibi; after three days of deliberation, a jury convicted Snyder of first-degree murder (premeditation). He received life without parole to run from and after his federal sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of eyewitness-identification expert testimony | Commonwealth argued expert unnecessary; jury can assess identifications and judge had found array non-suggestive | Snyder argued Penrod’s testimony would explain memory, post-identification effects, photo-array flaws, and confidence bias | Court upheld judge’s discretion to exclude Penrod: expert not sufficiently relevant to the specific identifications and would not aid jurors; no reversible error or prejudice |
| Admissibility of testimony/demo of stocking cap | Commonwealth argued cap corroborated Emma’s confession (showed mask-wearing) and was relevant | Snyder argued it was impermissible evidence of other bad acts and suggested the cap was the murder mask without foundation | Court allowed officer’s testimony and demonstration: probative to corroborate confession and not outweighed by prejudice; within trial judge’s discretion |
| Sufficiency of evidence / § 33E relief | Commonwealth relied on combined motive, confession, identifications, and corroboration | Snyder argued identifications were weak/consistent with alibi and Emma’s account unreliable; sought reversal in interest of justice | Court found evidence sufficient; declined to exercise § 33E to overturn or reduce conviction |
| Sentencing timing (concurrent vs consecutive) | Commonwealth/Trial judge imposed life to run from and after federal sentence, but judge invited a post-rescript motion to reconsider timing | Snyder requested concurrent timing and timely filed a revise-and-revoke motion under Mass. R. Crim. P. 29 | Court affirmed conviction but remanded to Superior Court to decide Snyder’s pending motion to revise/revoke sentence (trial judge retained authority) |
Key Cases Cited
- Daubert v. Merrell Dow Pharms., Inc., 509 U.S. 579 (federal standard for admissibility of expert scientific testimony)
- Commonwealth v. Lanigan, 419 Mass. 15 (state guidance on expert admissibility/Daubert principles)
- Commonwealth v. Santoli, 424 Mass. 837 (expert opinion must be reliable and relevant to identification circumstances)
- Commonwealth v. Watson, 455 Mass. 246 (admission of eyewitness-identification expert is discretionary)
- Commonwealth v. Gomes, 470 Mass. 352 (limitations of eyewitness ID and value of expert testimony)
- Commonwealth v. Collins, 470 Mass. 255 (distinctions between pretrial photo identifications and in-court showups)
- Commonwealth v. Alphas, 430 Mass. 8 (harmless-error analysis for excluded expert testimony)
- Commonwealth v. Carey, 463 Mass. 378 (standard for relevance and probative value of evidence of other acts)
- Commonwealth v. Franklin, 465 Mass. 895 (scope of G. L. c. 278, § 33E and appellate review limits)