Commonwealth v. Beatty

CourtMassachusetts Supreme Judicial Court
DecidedMay 25, 2023
DocketSJC 13158
StatusPublished

This text of Commonwealth v. Beatty (Commonwealth v. Beatty) 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.

Bluebook
Commonwealth v. Beatty, (Mass. 2023).

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NOTICE: All slip opinions and orders are subject to formal revision and are superseded by the advance sheets and bound volumes of the Official Reports.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-13158

COMMONWEALTH vs. JOSEPH W. BEATTY.

Norfolk. March 10, 2023. - May 25, 2023.

Present: Budd, C.J., Gaziano, Lowy, Cypher, & Wendlandt, JJ.

Homicide. Criminal Responsibility. Practice, Criminal, Capital case, Competency to stand trial, Instructions to jury.

Indictments found and returned in the Superior Court Department on October 1, 2009.

The cases were tried before Thomas A. Connors, J.

Theodore F. Riordan (Deborah Bates Riordan also present) for the defendant. Pamela Alford, Assistant District Attorney, for the Commonwealth.

WENDLANDT, J. The defendant, Joseph W. Beatty, was

convicted of one count of murder in the first degree on the

theories of deliberate premeditation, extreme atrocity or

cruelty, and felony-murder in connection with the 2009 killing

of his girlfriend, Mary Beaton (victim), in her Quincy 2

apartment.1 The defendant admitted to killing the victim, whom

he strangled and, later, asphyxiated with a pillow; however, he

contended that, due to his mental condition at the time of the

murder, he lacked criminal responsibility for her death.

On his direct appeal, the defendant maintains that the

trial judge abused his discretion in finding the defendant

competent to stand trial over defense counsel's objections, and

that the jury instructions concerning the consequences of a

verdict of not guilty due to lack of criminal responsibility,

while conforming to the then-applicable model jury instructions,

were prejudicial. He also asks the court to exercise its

authority under G. L. c. 278, § 33E, to reduce the degree of

guilt or order a new trial.

Having carefully reviewed the defendant's claims of error,

as well as the entire record, we affirm the conviction and

discern no reason to grant relief under G. L. c. 278, § 33E.

1. Background. The following facts are supported by the

evidence presented at trial.

a. The Commonwealth's case. On August 29, 2009, around

1:13 P.M., the defendant, his brother, two sisters, and niece

entered the emergency room at Boston Medical Center. The

defendant was wearing a "raggedy" yellow T-shirt, which was

1 He also was convicted of one count of aggravated rape in violation of G. L. c. 265, § 22 (a). 3

covered in blood. He had blood around his neck and wrist, and

cuts to his wrist and hands.

At the hospital, the group approached uniformed Boston

police Officer Daniel Quintiliani. The defendant's brother told

Quintiliani that he needed to speak with the officer because the

defendant "did a bad thing." Quintiliani asked the defendant

what he had done. The defendant replied, "I strangled a girl in

her apartment." The defendant provided Quintiliani with the

victim's name and her address in Quincy. Upon request for

identification, the defendant produced his own driver's license

and an identification card in the victim's name. Quintiliani

radioed dispatch to request a well-being check on the victim.

The defendant appeared calm, and Quintiliani had no difficulty

speaking with him. The defendant's brother removed a knife from

the defendant's pocket and gave it to Quintiliani.

Thereafter, the defendant entered the hospital's triage

unit. When a nurse asked him why he was there, the defendant

answered that he had strangled his friend after an argument over

finances. The defendant denied experiencing visual or auditory

hallucinations and noted that he was a kidney transplant

recipient. He also reported that he had experienced suicidal

ideation.

Quintiliani's partner, Boston police Officer Daniel

Korenetsky, who had arrived at the triage area, provided Miranda 4

warnings to the defendant;2 the defendant indicated that he

understood and proceeded to ask Korenetsky whether police had

found the victim. Korenetsky answered in the negative, to which

the defendant replied, "[T]hey're going to have to kick the door

in." A short time later, Quintiliani learned that Quincy police

had found the deceased victim's body in her apartment.

At 1:29 P.M., shortly after Korenetsky had provided the

defendant with Miranda warnings, Boston police Detectives Joseph

Leeman and Daniel MacDonald arrived at the triage area. The

detectives identified themselves and asked the defendant what

had happened. The defendant told them that, between 5 P.M. and

5:30 P.M. the prior day, he "just snapped" and choked his

girlfriend at her apartment. At that point, Leeman and

MacDonald stopped the conversation, provided Miranda warnings to

the defendant, and handcuffed him. The defendant said that he

understood his rights and wanted to speak to the officers;

MacDonald left to get a tape recorder. By 1:43 P.M., Boston

police Detective Daniel Keeler arrived at the hospital; he also

recited the Miranda warnings to the defendant. Five minutes

later, MacDonald returned from the police station with a tape

recorder.

When his brother offered to get the defendant a lawyer, 2

the defendant replied, "What do I need a lawyer for, to get eighty years instead of a hundred years?" 5

The defendant told the officers that on the day of the

killing, he went to the victim's apartment, where they drank a

couple of beers, shared a valium pill, and argued about money.

In particular, the victim was disappointed that they could not

afford a trip to Las Vegas; she informed the defendant that she

needed $500 for rent and proposed a less expensive trip to New

York. At that point, the defendant "just snapped." He grabbed

the victim's throat and began to strangle her; when she fell to

the floor, the defendant "had sex" with the victim and carried

her into the bedroom. The defendant saw white foam coming from

the victim's lips, after which he covered her face with a pillow

until she stopped breathing. The defendant placed a cross on

the victim, placed crucifixes on both sides of her body, put her

underwear on her, and covered her with a blanket. Before

leaving the apartment, the defendant took knives to "take care

of himself."

The defendant visibly was upset as he spoke; he added that

"my brain was just doing what it was doing; I had no control

over it." In response to a question by police that he had to be

angry, the defendant stated: "[Y]eah, I know but I don't know

what made me angry. . . . I've never had that anger in my

life." After a psychiatric resident evaluated the defendant and

determined that he did not require inpatient care, the defendant

was released to police custody. 6

i. Defendant's activities before and after killing. A few

days before the killing, between August 26 and August 28, 2009,

the defendant was at Foxwoods Casino with one of his sisters,

his niece, and four of his niece's children. On the morning of

August 28, the last day of the trip and the day of the murder,

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