Commonwealth v. Wright
469 Mass. 447
Mass.2014Background
- Commonwealth charged Wright with first-degree murder (1984).
- Trial conviction affirmed in 1992; multiple motions for new trial denied.
- In 2012 Wright filed fifth motion for a new trial based on purported newly discovered third-party culprit evidence (Rivera/Smalls).
- Rivera testified in Federal court that Smalls confessed and threatened to kill her; testing of a knife showed blood but was inconclusive.
- A gatekeeper proceeding under G. L. c. 278, § 33E allowed appeal on the newly discovered-evidence issue.
- The trial court denied the fifth motion; single justice allowed review; the Supreme Judicial Court affirmed the denial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Wright’s fifth motion for a new trial was rightly denied. | Wright asserts Rivera's testimony constitutes newly discovered third-party culprit evidence cast real doubt. | Commonwealth contends the evidence is not admissible or not sufficiently substantial to cast doubt. | No; the motion court did not err; new evidence not likely to change outcome. |
| Admissibility and weight of Rivera and Britt testimony as third-party culpability evidence. | Rivera/Britt testimony plausibly implicates Smalls, not Wright. | Evidence is hearsay or insufficiently connected to implicate Smalls; risk of prejudice. | Some portions inadmissible; overall weight insufficient to cast real doubt. |
| Whether the cumulative weight of admissible new-evidence could create substantial risk of miscarriage of justice. | Combined new evidence could produce reasonable doubt about Wright’s guilt. | Trial evidence overwhelmingly supports Wright; new evidence does not create potential acquittal. | No; new evidence does not create substantial risk of miscarriage. |
| Whether the Federal actual-innocence framework governs review of state postconviction relief in this context. | Rivera evidence demonstrates actual innocence under Schlup/House standards. | Actual innocence not a federal habeas gateway for state postconviction review here. | Court adheres to state-law gatekeeper standard; does not disturb denial. |
| Did the trial court abuse discretion in excluding certain Rivera/Britt testimony or in evaluating credibility? | Credibility determinations favored admissibility of Rivera/Britt evidence. | Court properly weighed credibility and admissibility. | No reversible error; discretion used within established standards. |
Key Cases Cited
- Commonwealth v. Randolph, 438 Mass. 290 (Mass. 2002) (gatekeeper review for new trial claims; substantial-question standard)
- Commonwealth v. Grace, 397 Mass. 303 (Mass. 1986) (newly discovered evidence with materiality and diligence requirements)
- Commonwealth v. Weichell, 446 Mass. 785 (Mass. 2006) (standard for evaluating new-trial motions based on new evidence)
- Commonwealth v. Silva-Santiago, 453 Mass. 782 (Mass. 2009) (third-party culprit evidence admissibility framework)
- Commonwealth v. Gagnon, 408 Mass. 185 (Mass. 1990) (testimony of an unavailable declarant and hearsay exceptions)
- Commonwealth v. Bizanowicz, 459 Mass. 400 (Mass. 2011) (limits on use of third-party evidence showing motive/relationship)
- Commonwealth v. Tobin, 392 Mass. 604 (Mass. 1984) (limits on propensity evidence in third-party culpability context)