Commonwealth v. Dara Poum

CourtMassachusetts Supreme Judicial Court
DecidedJuly 9, 2025
DocketSJC-13443
StatusPublished

This text of Commonwealth v. Dara Poum (Commonwealth v. Dara Poum) 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. Dara Poum, (Mass. 2025).

Opinion

SUPREME JUDICIAL COURT

COMMONWEALTH vs. DARA POUM

Docket: SJC-13443
Dates: March 7, 2025 - July 9, 2025
Present: Budd, C.J., Kafker, Wendlandt, Georges, & Wolohojian, JJ.
County: Middlesex
Keywords: Homicide. Felony-Murder Rule. Armed Home Invasion. Firearms. Evidence, Argument by prosecutor. Practice, Criminal, Argument by prosecutor, Opening statement, Instructions to jury, Sentence, Assistance of counsel, Duplicative convictions, Capital case. License.

            Indictments found and returned in the Superior Court Department on December 10, 2014.

            The cases were tried before Robert L. Ullmann, J.

            Andrew S. Crouch for the defendant.

            Chia Chi Lee, Assistant District Attorney, for the Commonwealth.

            WOLOHOJIAN, J.  In the early morning hours of Sunday, August 10, 2014, the defendant entered an apartment on Andrews Street in Lowell and shot and killed two of its occupants.  After a jury trial, the defendant was convicted of felony-murder, G. L. c. 265, § 1; armed home invasion, G. L. c. 265, § 18C; and possession of a firearm without a license, G. L. c. 269, § 10 (a).  The defendant raises several arguments in this direct appeal.  First, he argues that the jury should not have been instructed that, with respect to felony-murder, the Commonwealth was not required to prove the absence of mitigating circumstances, specifically reasonable provocation by sudden combat.  Second, he asserts that the prosecutor impermissibly appealed to emotion in his opening statement and closing argument.  Third, the defendant contends that the judge prejudged the sentences prior to the sentencing hearing, and that defense counsel was ineffective for failing to present any mitigating information at sentencing.  Fourth, the defendant argues, and the Commonwealth concedes, that his conviction of armed home invasion must be vacated as duplicative because it was the predicate felony for the felony-murder conviction.  Fifth, the defendant argues, and the Commonwealth acknowledges, that the firearm conviction must be vacated because the jury were not instructed that the Commonwealth bore the burden to prove beyond a reasonable doubt that he did not possess a firearms license, and the Commonwealth failed to introduce any evidence on the issue.  Finally, the defendant asks that we exercise our authority under G. L. c. 278, § 33E, to reduce the verdicts of murder in the first degree to manslaughter or murder in the second degree, or to grant other appropriate relief. 

            We vacate and set aside, without need for further discussion, the defendant's conviction of armed home invasion because it is duplicative of the felony-murder conviction for which it served as the predicate felony.  See Commonwealth v. Alcequiecz, 465 Mass. 557, 568 (2013), quoting Commonwealth v. Rasmusen, 444 Mass. 657, 666 (2005) ("When a murder conviction is based on a felony-murder theory, the underlying felony, whatever it may be, is always a lesser included offense and the conviction for that felony, in addition to the conviction of murder, is duplicative").  Also, without further discussion, we vacate the defendant's conviction of unlawful possession of a firearm because the jury were not instructed that the Commonwealth bore the burden to prove lack of licensure and presented no evidence on that point; we remand for further proceedings on the firearm charge.[1]  See Commonwealth v. Guardado, 493 Mass. 1, 12 (2023), cert. denied, 144 S. Ct. 2683 (2024).  For the reasons explained below, we affirm the two felony-murder convictions.

            Background.  We briefly summarize the facts as the jury could have found them, reserving additional details for our discussion of the issues raised on appeal. 

            On Saturday, August 9, 2014, the defendant went to his girlfriend's family's house located on Andrews Street in Lowell, where he spent the afternoon and evening "hanging out," drinking, and eating.  During the early hours of Sunday morning, while this gathering was still underway, the defendant's girlfriend's sister saw the defendant holding a firearm in one hand and a clip in the other.  She snatched the clip from him, saw that it contained a bullet, and then attempted to retain it despite his repeated demands for its return.  Ultimately, the girlfriend's sister acquiesced and returned the clip to the defendant.  The defendant then left the party for twenty minutes.  When he returned, his shirt was spotted with blood, his hair was disheveled, his forehead had a scratch, and he was breathing hard and sweating.  When the girlfriend asked about this state of affairs, the defendant said that he had gotten into an argument with the neighbors after they had called him names and swore at him.

            In fact, the defendant had gone two doors down Andrews Street, where he entered a second-floor apartment through its back door at approximately 1:45 A.M. and herded its three adult occupants into a small bathroom where he shot and killed Keith and Joseph Callahan at close range.[2]  There was no known connection between the defendant and his victims.

            The defendant's girlfriend confronted him after seeing news of the murders a few days later, including a police sketch resembling the defendant.  He admitted to her that he had shot the gun in the neighbors' apartment, that he had buried the gun in her father's backyard, and that he had hidden his sneakers in her mother's closet.  The defendant said, however, that he did not know who or what he may have hit, and that he hoped no one had been hurt.  Nonetheless, the defendant predicted that he would be sent to jail for a long time.  The police located the gun (a semiautomatic pistol) and the sneakers where the defendant said he had hidden them.  Ballistics testing showed that the spent projectiles recovered from Keith's body and from the bathroom where the killings took place came from the semiautomatic pistol the defendant buried in the garden.  Testing determined that the deoxyribonucleic acid profile of the blood found on the defendant's sneaker matched that of Keith.

            The defendant was indicted of two counts of murder in the first degree:  one count pertained to Keith, who died at the scene, and the other pertained to Joseph, who died while being transported to a hospital.  The defendant was also indicted for armed home invasion, with Joseph's girlfriend, Jessica Kelly, named as the victim.  Finally, the defendant was charged with unlawful possession of a firearm.

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