Commonwealth v. Williams
475 Mass. 705
| Mass. | 2016Background
- On Jan 22, 2010, Demery Williams drove victim William Jones to a Springfield house where Jones was led to meet Curtis Combs; Williams acted as a lookout and later drove Jones in a white Saturn to a Bloomfield grocery lot where Jones's body was found; cause of death: ligature strangulation.
- Williams gave varying statements to Connecticut police (audio-recorded secretly under CT law), initially denying involvement, later admitting he lured Jones, saw Combs use a stun gun, served as lookout, and drove Jones to Bloomfield; he signed written statements.
- DNA from a latex glove fingertip and a headrest in the Saturn contained contributors matching both Jones and Williams; Williams routinely used similar latex gloves at work.
- Investigation slowed; Massachusetts indicted Williams in Sept 2011; he was tried in Hampden County and convicted as a joint venturer of first-degree murder (felony-murder and extreme atrocity/cruelty), armed robbery, and A&B with a dangerous weapon.
- At trial the Commonwealth admitted Williams’s recorded statements, CSLI and call records (from warrants obtained in CT), substitute medical examiner testimony (reviewing autopsy photos and report), and DNA testing results; Williams raised speedy-trial, confrontation, evidentiary, and preservation claims on appeal.
Issues
| Issue | Plaintiff's Argument (Commonwealth) | Defendant's Argument (Williams) | Held |
|---|---|---|---|
| Sufficiency — joint venturer / felony-murder | Evidence (statements, DNA, CSLI, conduct) permits inference Williams knowingly participated and shared intent in armed robbery leading to death | Insufficient proof he joined armed robbery, knew Combs was armed, or that property was taken; insufficient link to death | Affirmed: evidence sufficient for joint venturer liability for felony-murder and extreme atrocity/cruelty theories |
| Extreme atrocity/cruelty mens rea | Presence, participation, glove/DNA, statements, and brutality (stun gun, sustained strangulation) support malice and extreme cruelty | He did not participate in ligature strangulation and lacked requisite mental state | Affirmed: jury reasonably could find presence, willingness to assist, malice, and Cunneen factors met |
| Speedy trial (Mass. R. Crim. P. 36) | Delays were partly agreed to by defense; several continuances were jointly requested | Delay (arraignment to motion >12 months) violated rule; dismissal required | Affirmed denial of dismissal: defendant established prima facie delay but Commonwealth proved >152 days excluded by defendant’s acquiescence/benefit |
| Admission of recorded statements (secret CT recordings) | Recordings admissible (made in CT where secret recording lawful); transcripts and redacted audio properly authenticated; cautionary instruction given | Recordings incomplete, secretly made in MA not warrantable under Mass. c.272 §99; transcripts improperly used in lieu of recordings | Affirmed: admissible under CT law; incompleteness addressed by cautionary instruction; manner of admission within discretion |
| Substitute medical examiner / confrontation / expert reliability | Substitute pathologist may testify to her independent opinion based on autopsy photos/reports; defendant had cross-examination opportunity | Use of substitute (original autopsy examiner available) violated Confrontation Clause and testimony unreliable because she did not perform autopsy; missing-witness instruction required | Affirmed: no Confrontation violation (no testimonial out-of-court statements offered); substitute opinion admissible; missing-witness instruction not warranted given Commonwealth's tactical reason |
| CSLI / call records — warrant and authentication | Records were obtained under CT warrants and properly authenticated as business records; qualified witness competent to interpret them | Records obtained without proper warrants (Fourth Amendment/18 U.S.C. §2703); counsel ineffective for not objecting | Affirmed: warrants shown in record; admission and witness testimony not erroneous |
| DNA evidence / loss of raw swab material | Lab consumed raw swab during retesting before MA involvement; extracted DNA remained and was available; Commonwealth had no control when raw was consumed | Commonwealth violated preservation duty; inability to test raw DNA or observe extraction prejudiced defense | Affirmed: prosecutor’s preservation duty did not extend to CT lab acts before MA involvement; no bad faith shown; extracted material was available and defendant didn’t seek continuance |
Key Cases Cited
- Commonwealth v. James, 424 Mass. 770 (standard for required finding motion)
- Commonwealth v. Latimore, 378 Mass. 671 (evidence viewed in light most favorable to prosecution)
- Commonwealth v. Zanetti, 454 Mass. 449 (joint venturer standards for conviction)
- Commonwealth v. DiGiambattista, 442 Mass. 423 (incomplete recordings require cautionary instruction not automatic exclusion)
- Commonwealth v. Reavis, 465 Mass. 875 (substitute examiner may opine based on autopsy report/photos)
- Commonwealth v. Cunneen, 389 Mass. 216 (factors for extreme atrocity or cruelty)
- Commonwealth v. Roman, 470 Mass. 85 (Rule 36 computation and acquiescence/excludable delay)
- Commonwealth v. Lanigan, 419 Mass. 15 (gatekeeping standard for scientific expert testimony)