Commonwealth v. Arthur Mudde.

CourtMassachusetts Appeals Court
DecidedApril 17, 2026
Docket25-P-0786
StatusUnpublished

This text of Commonwealth v. Arthur Mudde. (Commonwealth v. Arthur Mudde.) 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. Arthur Mudde., (Mass. Ct. App. 2026).

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

25-P-786

COMMONWEALTH

vs.

ARTHUR MUDDE.

MEMORANDUM AND ORDER PURSUANT TO RULE 23.0

After a jury trial, the defendant was convicted of

aggravated rape as a joint venturer with his codefendant, Duc

Minh La.1 On appeal, he claims that he received ineffective

assistance of counsel, the prosecutor made misstatements of the

evidence in her closing argument, and that several witnesses

gave improper cumulative first complaint testimony. We affirm.

1. Ineffective assistance of counsel. The defendant

claims for the first time on appeal that he was deprived of

effective assistance of counsel where his trial counsel did not

present an expert witness to explain alternative possibilities

1The defendant was acquitted of a second count of aggravated rape. as to how the defendant's deoxyribonucleic acid (DNA) could have

been found on the victim's genital area. We disagree.

Claims of ineffective assistance of counsel are disfavored

if they are raised for the first time on direct appeal.

Commonwealth v. Zinser, 446 Mass. 807, 811 (2006). The

exception to this is "when the factual basis of the claim

appears indisputably on the trial record." Commonwealth v. Keon

K., 70 Mass. App. Ct. 568, 573–574 (2007). We are not convinced

that this case falls within the exception.

It is not clear from the record how expert testimony would

have rebutted the evidence against the defendant. Indeed,

because the defendant did not raise this claim in a motion for

new trial, we have no affidavits or testimony from trial counsel

whether his acts or omissions were part of his trial strategy,

nor do we have an affidavit outlining what the testimony of a

putative expert would have been, and we do not have findings

from the trial judge as to the likely impact of this omission.

See Commonwealth v. Alicea, 464 Mass. 837, 850-851 (2013)

(ineffective assistance claim based on failure to call expert

"generally doomed" if not supported by expert's affidavit

disclosing content of potential testimony); Commonwealth v.

Adamides, 37 Mass. App. Ct. 339, 344 (1994) (when counsel fails

to call certain witnesses at trial, record alone provides

2 "insufficient factual basis for appellate review"). Because the

defendant's claim of ineffective assistance of counsel on direct

appeal fails to appear indisputably on the record, we decline to

resolve it.2

2. The prosecutor's closing argument. The defendant also

claims that the prosecutor made three material misstatements of

the evidence in her closing argument which requires a new trial.

We disagree.

The first claimed misstatement is that the prosecutor

improperly attributed the selection of the Casamigos tequila to

the defendant. As the defendant did not object to the

prosecutor's remark at trial, we review to determine if there

was error, and if so, whether it created a substantial risk of a

miscarriage of justice. See Commonwealth v. Desiderio, 491

Mass. 809, 815 (2023). There was no error.

2 In any event, we conclude that the omitted expert testimony did not create a substantial risk of a miscarriage of justice. See Commonwealth v. Curtis, 417 Mass. 619, 624 n.4 (1994) (if counsel's omission does not present substantial risk of miscarriage of justice, no basis for ineffective assistance of counsel claim). The jury convicted the defendant on a joint venture theory, suggesting that the presence of the defendant's own DNA on the victim's genitals was immaterial to that conviction. In addition, the defendant's counsel presented his DNA transfer theory through cross-examination of the Commonwealth's DNA experts, and argued it in his closing argument. Because "the jury were provided with essentially expert testimony on the subjects on which the defendant claims he needed expert opinion," Alicea, 464 Mass. at 851, there was no risk that justice miscarried.

3 The defendant claims that it was the female guests at the

nightclub who requested the Casamigos tequila. That much is

true. Nightclub personnel informed Kearvyn Arne, the

defendant's friend, that, given the number of people at the

table, Arne would have to purchase another bottle of alcohol.

Arne sent a text message to the defendant to ask what type of

alcohol he should purchase, because "the girls" wanted Casamigos

tequila while some of the defendant's friends preferred Hennessy

cognac. The defendant responded to Arne that, if he wanted "us

to hit," i.e., to have sex with the women, that Arne should

purchase the Casamigos because it was "more strong."

Accordingly, the defendant was involved in the selection of the

tequila, and the text messages revealed the reason why. There

was no misstatement.

The defendant next claims, also for the first time on

appeal, the prosecutor's argument improperly connected the

condoms in the defendant's bathroom to the rape. We disagree.

At trial, the victim testified that before the defendant

raped her, he "fidget[ed] with his hands and like sort of

open[ed] something up. [She could] tell he was taking out a

condom." The victim added that he was fidgeting with his hands

near his genital area. From this evidence, it was a reasonable

inference that the condom found in the defendant's bathroom

4 trash receptacle was connected to the rape. See Commonwealth v.

Francis, 450 Mass. 132, 142 (2007). After all, "inferences that

support a conviction 'need only be reasonable and possible;

[they] need not be necessary or inescapable.'" Commonwealth v.

Sabin, 104 Mass. App. Ct. 303, 305 (2024), quoting Commonwealth

v. Howe, 103 Mass. App. Ct. 354, 357 (2023). The inference the

prosecutor drew was proper.

Despite this, the defendant maintains that the argument was

nonetheless improper because an earring found in the trash with

the condoms did not belong to the victim. But this argument is

a non sequitur fallacy. It does not logically follow that

because one item in the trash was not connected to the rape, the

other items in the trash could not be connected to the rape.

There were a number of people at the "after party" in the

defendant's apartment, and the earing could easily have been

discarded by one of them or by someone on a different occasion.

There was no error, and thus, no risk that justice miscarried.

The defendant further claims the prosecutor unfairly argued

that the defendant removed the victim's underwear. The

defendant specifically objected to the prosecutor arguing that

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Related

Commonwealth v. Curtis
632 N.E.2d 821 (Massachusetts Supreme Judicial Court, 1994)
Commonwealth v. Adamides
639 N.E.2d 1092 (Massachusetts Appeals Court, 1994)
Commonwealth v. Dargon
930 N.E.2d 707 (Massachusetts Supreme Judicial Court, 2010)
Commonwealth v. McCoy
926 N.E.2d 1143 (Massachusetts Supreme Judicial Court, 2010)
Commonwealth v. Aviles
958 N.E.2d 37 (Massachusetts Supreme Judicial Court, 2011)
Commonwealth v. Rutherford
71 N.E.3d 481 (Massachusetts Supreme Judicial Court, 2017)
Commonwealth v. Cruz
839 N.E.2d 324 (Massachusetts Supreme Judicial Court, 2005)
Commonwealth v. Zinser
847 N.E.2d 1095 (Massachusetts Supreme Judicial Court, 2006)
Commonwealth v. Francis
876 N.E.2d 862 (Massachusetts Supreme Judicial Court, 2007)
Commonwealth v. Arana
901 N.E.2d 99 (Massachusetts Supreme Judicial Court, 2009)
Commonwealth v. Alicea
985 N.E.2d 1197 (Massachusetts Supreme Judicial Court, 2013)
Commonwealth v. Keon K.
875 N.E.2d 498 (Massachusetts Appeals Court, 2007)
Chace v. Curran
881 N.E.2d 792 (Massachusetts Appeals Court, 2008)
COMMONWEALTH v. GUSTAVO GONZALEZ SANTOS.
100 Mass. App. Ct. 1 (Massachusetts Appeals Court, 2021)

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