Commonwealth v. Bateman

CourtMassachusetts Supreme Judicial Court
DecidedFebruary 20, 2026
DocketSJC 10079
StatusPublished

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

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Commonwealth v. Bateman, (Mass. 2026).

Opinion

NOTICE: All slip opinions and orders are subject to formal revision and are superseded by the advance sheets and bound volumes of the Official Reports. If you find a typographical error or other formal error, please notify the Reporter of Decisions, Supreme Judicial Court, John Adams Courthouse, 1 Pemberton Square, Suite 2500, Boston, MA, 02108-1750; (617) 557- 1030; SJCReporter@sjc.state.ma.us

SJC-10079

COMMONWEALTH vs. DENNIS M. BATEMAN.

Franklin. October 14, 2025. - February 20, 2026.

Present: Budd, C.J., Kafker, Wendlandt, Georges, & Wolohojian, JJ.

Homicide. Evidence, Sound recording, Disclosure of evidence, Exculpatory, Impeachment of credibility, Expert opinion. Practice, Criminal, Disclosure of evidence, Assistance of counsel, New trial. Witness, Impeachment, Expert.

Indictments found and returned in the Superior Court Department on July 8, 2005.

Following review by this court, 492 Mass. 404 (2023), a motion for a new trial, filed on December 4, 2020, was heard by John A. Agostini, J.

Amy L. Codagnone for the defendant. Steven E. Gagne, Assistant District Attorney, for the Commonwealth.

KAFKER, J. The defendant, Dennis M. Bateman, was convicted

of two counts of murder in the first degree for the deaths of

Brandy Waryasz and her viable, unborn child. The defendant

appealed from the convictions and filed a motion for a new trial 2

alleging numerous issues, which we remitted to the Superior

Court. The motion judge, who was also the trial judge, denied

the motion, and the defendant appealed. The direct appeal was

joined with the appeal from the denial of the motion for a new

trial. After plenary review, we affirmed the murder convictions

and the denial of the motion for a new trial, and we declined to

grant extraordinary relief pursuant to G. L. c. 278, § 33E. See

Commonwealth v. Bateman, 492 Mass. 404, 405-406 (2023).

While the consolidated appeal was pending, the defendant

filed a second motion for a new trial, and he amended that

motion twice prior to the issuance of the rescript for the

consolidated appeal. We remitted the second motion for a new

trial to the Superior Court; the same judge who had presided at

the trial denied the motion, and the defendant appealed. The

defendant now argues that the judge erred in concluding he was

not entitled to a new trial due to (1) the Commonwealth's

failure to disclose a segment of an audio recording of a police

interview with a potential trial witness, (2) newly discovered

anomalies that cast doubt on the authenticity of audio

recordings of the defendant's second interview with police

officers, or (3) ineffective assistance of both trial and prior

appellate counsel. We affirm. 3

1. Background. We present the relevant factual background

as proven at trial,1 as well as the procedural history. We

reserve certain facts from the record for the instant appeal for

later discussion.

a. The homicide. On Saturday, April 16, 2005, Waryasz,

who was thirty to thirty-two weeks pregnant, was working a shift

from 2 P.M. to 9 P.M. as the sole attendant at a gasoline

station located in Deerfield. The defendant, a forty year old,

African-American man with a history of "crack" cocaine use,

stopped by the gasoline station during Waryasz's shift --

although his precise arrival and departure times are unclear.

Between 5 P.M. and 6:30 P.M., however, several witnesses saw the

defendant's distinctive, black 1988 Ford Econoline van parked

outside of the gasoline station's office building and the

defendant speaking to Waryasz.2 During a lull in customers

sometime around 6:30 P.M., the defendant attacked Waryasz,

1 The evidence presented in the defendant's trial is summarized in more detail in Commonwealth v. Bateman, 492 Mass. 404, 406-410 (2023). We provide a condensed version of events here, with a particular focus on facts, as the jury could have found them, relevant to the issues before us.

2 One of these witnesses was David Williams, who reported seeing the van at approximately 6:30 P.M. Williams "immediately" recognized the van as the defendant's because he had sold black spray paint to the defendant, and when making the purchase, the defendant showed Williams the van and said he intended to paint his van black. Williams thus recognized the van's distinctive "spray can paint job." 4

tightly wrapping a ligature -- a black nylon-like belt or strap

-- around her neck and tying it in a knot in the rear. He left

her lying in one of the gasoline station's service bays, took

the cash register to his van, and drove away. At approximately

6:42 P.M., a customer entered the gasoline station's office

building to purchase gasoline but found no one inside. The

customer then walked into the service bay adjoining the office

and found Waryasz's body lying on the ground. Both Waryasz and

her unborn child died as a result of the ligature cutting off

Waryasz's airflow. The cash register, as well as the

approximately $350 that had been in it, were never recovered.

The defendant, meanwhile, had driven back to Greenfield.

He was observed with "lots of money" at various points

throughout the night, and he purchased and smoked $250 worth of

crack cocaine with multiple companions. The defendant also

periodically asked his companions to make sure his family was

taken care of "if anything happen[ed] to him" because he had

"messed things up." In the days that followed, the defendant

pressed some of those he encountered on April 16 to confirm that

he was in Greenfield at or about the time of the murders. All

those he approached, however, had seen him either before or

after the time of the murders.

b. The investigation. On April 18, 2005, police officers

interviewed the defendant at the district attorney's office in 5

Greenfield. Approximately the first hour of the interview was

not audio recorded. Instead, police drafted a written statement

based on what the defendant revealed during that hour, which the

defendant reviewed, signed, and then read aloud so that it could

be audio recorded. While at the district attorney's office, the

defendant made several unsolicited, incriminating statements to

the officers. The defendant told one interviewing officer, "You

know, we were only horsing around, [Waryasz] and I, pushing and

shoving." The officer asked the defendant what he meant, and

the defendant explained that Waryasz had been snapping a black

belt at him. The defendant had not mentioned the belt during

the interview, and the police had not yet publicly disclosed

that Waryasz had been strangled. Shortly thereafter, the

defendant again brought up the belt without prompting when

another interviewing officer drove him back to his house. These

statements led the officers to identify the defendant as a

potential person of interest. Two days later, on April 20,

2005, the defendant agreed to a follow-up interview at the

district attorney's office with Detective Lieutenant John

Gibbons and Sergeant Gary Gadreault. Unlike his first

interview, this interview was recorded.

Later in the investigation, a deoxyribonucleic acid (DNA)

profile was generated from the biological material found on the

ligature with which Waryasz was strangled. Analysis of the 6

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