Commonwealth v. Adam T. Liccardi.

CourtMassachusetts Appeals Court
DecidedSeptember 30, 2024
Docket23-P-0631
StatusUnpublished

This text of Commonwealth v. Adam T. Liccardi. (Commonwealth v. Adam T. Liccardi.) is published on Counsel Stack Legal Research, covering Massachusetts Appeals Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Commonwealth v. Adam T. Liccardi., (Mass. Ct. App. 2024).

Opinion

NOTICE: Summary decisions issued by the Appeals Court pursuant to M.A.C. Rule 23.0, as appearing in 97 Mass. App. Ct. 1017 (2020) (formerly known as rule 1:28, as amended by 73 Mass. App. Ct. 1001 [2009]), are primarily directed to the parties and, therefore, may not fully address the facts of the case or the panel's decisional rationale. Moreover, such decisions are not circulated to the entire court and, therefore, represent only the views of the panel that decided the case. A summary decision pursuant to rule 23.0 or rule 1:28 issued after February 25, 2008, may be cited for its persuasive value but, because of the limitations noted above, not as binding precedent. See Chace v. Curran, 71 Mass. App. Ct. 258, 260 n.4 (2008).

COMMONWEALTH OF MASSACHUSETTS

APPEALS COURT

23-P-631

COMMONWEALTH

vs.

ADAM T. LICCARDI.

MEMORANDUM AND ORDER PURSUANT TO RULE 23.0

A Superior Court jury convicted the defendant of two counts

of aggravated rape and one count of rape. A panel of this court

affirmed the convictions but vacated a portion of the order

denying a new trial and, as to certain information the

Commonwealth erroneously withheld during discovery, remanded for

the same judge who had presided over the trial and new trial

motion to determine, in the exercise of his discretion, the

effect that omitted evidence would have had on the collective or

individual judgments of twelve lay people. On remand, the judge

denied the defendant's motion for a new trial after a

nonevidentiary hearing, concluding that the undisclosed evidence

"did not influence the jury, or had but very slight effect."

See Commonwealth v. Kostka, 489 Mass. 399, 411 (2022). The

defendant requested reconsideration and the judge held an evidentiary hearing at which the trial prosecutor, her second

chair, the defendant's trial counsel, and a codefendant's trial

counsel testified. Thirty-six exhibits were entered in evidence

and considered by the judge. Applying the proper standard, the

judge again denied the motion. The defendant appeals from the

order denying his motion for a new trial. He also claims error

in the prosecutor's closing argument, asserting that the issue

was not addressed in his first appeal. Finally, the defendant

appeals from the judge's order denying his motions for

postconviction discovery. We affirm.

Background. We summarize the facts presented to the jury,

reserving additional facts for later discussion. In the fall of

2012, the victim began her freshman year at the University of

Massachusetts (UMass). Sometime between 11 P.M. and midnight on

a Friday in October, the defendant and his three codefendants

arrived uninvited at the victim's dormitory. Although none of

the men attended UMass, security permitted them to enter the

building. The victim knew the four men but had not invited

them, and her friends had told them not to visit that evening.

The four men entered the victim's room and spent several hours

there consuming alcohol and marijuana that they had brought with

them. The victim became so intoxicated that she could not sit

up or walk without assistance. Eventually, the victim's friends

carried her to bed. When they left to sleep in their own room,

2 the victim was unconscious or asleep. Two of the men, including

the defendant, remained in the victim's room and the other two

returned a short time later.

The four men took turns sexually assaulting the victim in

her room while she passed in and out of consciousness. 1 After

three of the men left, the victim again passed out. She woke up

to the defendant penetrating her vagina with his penis.

In the morning, the victim woke up in severe pain and with

internal bleeding. She told a friend that she was sexually

assaulted by all four men. Later that day, the victim exchanged

text messages with one of the codefendants, Emmanuel Bile. In

one text message, the victim demanded $500 from the four men,

"[o]r else I'm taking you to court." 2 She also wrote, "Thank you

all for raping me while I was passed out and couldn't move."

The following day, the victim reported the rapes to police and

underwent a physical examination by a sexual assault nurse

examiner at a nearby hospital.

During the police investigation, the defendant initially

denied sexual contact with the victim. He told a detective that

1 Separate juries convicted each codefendant of aggravated rape.

2 The victim testified that she demanded the money because she did not want anyone, particularly her parents, to know about the rapes, but she wanted to be able to pay for her resulting medical expenses.

3 he kissed the victim at the same time his codefendant Justin

King had consensual vaginal sex with her. After the defendant

was informed that the victim had undergone a sexual assault

examination, he admitted to the detective that all four men

penetrated the victim's body with their penises, sometimes

simultaneously. The defendant acknowledged that his penis

penetrated the victim's mouth and vagina and stated that "it

[w]as a group thing." He admitted that the victim cried while

he was penetrating her vagina.

The defense at trial was that the victim was raped by Bile,

but any sex acts with the defendant were consensual and the

victim lied about being raped by all four men because she wanted

money.

Discussion. 1. Motion for a new trial. We review a

judge's decision on a motion for new trial for error of law or

abuse of discretion. See Commonwealth v. Tavares, 491 Mass.

362, 365 (2023). Where, as here, the motion judge was also the

trial judge, "we give special deference to the judge's findings

of fact and the ultimate decision on the motion" (quotation and

citation omitted). Commonwealth v. Corey, 493 Mass. 674, 684

(2024).

a. Egregiousness of the prosecutor's failure to disclose

the presentment letter. "Due process of law requires that the

government disclose to a criminal defendant favorable evidence

4 in its possession that could materially aid the defense against

the pending charges." Commonwealth v. Tucceri, 412 Mass. 401,

404-405 (1992). A panel of this court concluded that the

Commonwealth erroneously failed to disclose that, nearly two

years after the rapes, the victim's attorney sent a presentment

letter to the Attorney General's office as notice of the

victim's intent to file a lawsuit against UMass and other

government entities for damages resulting from the rapes. 3

The defendant first contends that the discovery violation

was so egregious that he should not have been required to

demonstrate prejudice. 4 "[P]rosecutorial misconduct that is

egregious, deliberate, and intentional, or that results in a

violation of constitutional rights may give rise to presumptive

prejudice" (citation omitted). Committee for Pub. Counsel

Servs. v. Attorney Gen., 480 Mass. 700, 724 (2018). This

"theory should be narrowly applied, and confined to situations

3 Under G. L. c.

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Commonwealth v. Adam T. Liccardi., Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-adam-t-liccardi-massappct-2024.