102 N.E.3d 961
Mass.2018Background
- Defendant Thomas A. Woods testified before a Brockton grand jury in Feb. 2006 investigating a Dec. 2005 homicide; he was not told he was a target or of his right against self-incrimination.
- His grand jury testimony was largely exculpatory and used at his 2009 trial to show inconsistent statements; he was convicted of first-degree murder and sentenced to life.
- At pretrial motions, Woods sought exclusion of his grand jury testimony, arguing he should have been warned if he was a target; the trial judge found he was not a target and denied the motion.
- On direct appeal (Woods I), the SJC upheld admission, found no obligation then to warn targets, but exercised superintendence to announce prospectively that prosecutors must warn witnesses who are targets or likely to become targets of their Fifth Amendment right before grand jury testimony.
- Woods later moved for a new trial, submitting previously unavailable grand jury testimony from witnesses who had testified before him (two of whom reported hearsay about threats by Woods), and the motion judge found these transcripts rendered Woods a target at the time he testified.
- The motion judge denied a new trial because Woods I was decided on legal grounds independent of the trial judge’s factual finding about target status; the SJC affirmed that denial.
Issues
| Issue | Plaintiff's Argument (Commonwealth) | Defendant's Argument (Woods) | Held |
|---|---|---|---|
| Whether Woods was a "target" when he testified before the grand jury | N/A (Commonwealth argued at trial he was not a target when called) | Woods argued newly submitted grand jury transcripts show he was a target when he testified | Motion judge found new transcripts made Woods a target, but SJC held resolution of that factual issue did not entitle Woods to relief because of the prospective rule announced in Woods I |
| Whether failure to warn Woods of target status/self-incrimination required excluding his grand jury testimony at trial | At the time, no legal obligation to warn; thus admission lawful | Failure to warn violated rights and testimony was improperly used at trial | SJC: No obligation existed at trial; Woods I created a prospective (nonconstitutional) rule, so retroactive relief not available |
| Whether Woods is entitled to a new trial on collateral review based on Woods I rule | Rule applies prospectively only; collateral relief not warranted | Woods seeks retroactive benefit of the new rule because he was actually a target | SJC: Denied collateral relief; Woods I expressly limited the rule to future cases, so no retroactivity |
| Whether trial judge’s factual finding about target status was outcome-determinative | Commonwealth: even if target, no duty to warn at that time | Woods: if he was a target, exclusion would have been required under later-announced rule | SJC: The court’s Woods I decision did not depend on the trial judge’s finding; even assuming target status, no relief because the new rule was nonconstitutional and prospective |
Key Cases Cited
- Commonwealth v. Woods, 466 Mass. 707 (Mass. 2014) (Woods I) (upheld admission of grand jury testimony and announced prospective rule requiring warnings to targets or likely targets)
- United States v. Washington, 431 U.S. 181 (U.S. 1977) (no federal obligation to warn grand jury targets at that time)
- Commonwealth v. D'Amour, 428 Mass. 725 (Mass. 1999) (relevant precedent on self-incrimination and evidence issues)
- Commonwealth v. Dagley, 442 Mass. 713 (Mass. 2004) (discussed in relation to pretrial and appellate practice)
- Commonwealth v. Adjutant, 443 Mass. 649 (Mass. 2005) (retroactivity discussion for common-law rules announced on direct appeal)