Commonwealth v. Desiderio

CourtMassachusetts Supreme Judicial Court
DecidedMay 4, 2023
DocketSJC 13338
StatusPublished

This text of Commonwealth v. Desiderio (Commonwealth v. Desiderio) 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. Desiderio, (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NOTICE: All slip opinions and orders are subject to formal revision and are superseded by the advance sheets and bound volumes of the Official Reports.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-13338

COMMONWEALTH vs. NICHOLAS DESIDERIO.

Worcester. February 8, 2023. – May 4, 2023.

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

Armed Home Invasion. Robbery. Joint Enterprise. Evidence, Joint venturer. Practice, Criminal, Instructions to jury.

Indictments found and returned in the Superior Court Department on March 3, 2015.

The cases were tried before Richard T. Tucker, J.

After review by the Appeals Court, the Supreme Judicial Court granted leave to obtain further appellate review.

MarySita Miles for the defendant. Nathaniel R. Beaudoin, Assistant District Attorney, for the Commonwealth.

LOWY, J. A jury in the Superior Court convicted the

defendant, Nicholas Desiderio, of one count of armed home

invasion and three counts of armed robbery while masked. The

indictments were based on a theory of joint venture. The jury, 2

however, were not instructed that, to convict the defendant of

those charges on a joint venture theory, the Commonwealth was

required to prove that the defendant knew that at least one

coventurer was armed (for the count of armed home invasion), and

that at least one coventurer was both armed and masked (for the

counts of armed robbery while masked). Those instructions were

required. See Commonwealth v. Bolling, 462 Mass. 440, 450

(2012).

The issue in this appeal is whether the failure to instruct

the jury of these requirements created a substantial risk of a

miscarriage of justice. To decide whether an error creates a

substantial risk of a miscarriage justice, we must determine "if

we have a serious doubt whether the result of the trial might

have been different had the error not been made." Commonwealth

v. Azar, 435 Mass. 675, 687 (2002), S.C., 444 Mass. 72 (2005),

quoting Commonwealth v. LeFave, 430 Mass. 169, 174 (1999). In

making this determination, we consider four factors, where

applicable: "[(1)] the strength of the Commonwealth's case,

[(2)] the nature of the error, [(3)] the significance of the

error in the context of the trial, and [(4)] the possibility

that the absence of an objection was the result of a reasonable

tactical decision." Azar, supra.

Although we recently have analyzed the question of

substantial risk of a miscarriage of justice where an element of 3

a crime has been omitted from the jury instructions by

determining whether "the evidence was 'so overwhelming' that

'there is no likelihood that the omitted instruction materially

influenced the jury's verdict[],'" Commonwealth v. Silvelo, 486

Mass. 13, 17-18 (2020), quoting Commonwealth v. Lutskov, 480

Mass. 575, 581 (2018), we now recognize that this formulation

confuses rather than accurately reflects the necessary

considerations of the substantial risk analysis in this context.

As in all contexts, where an element of the crime charged

has been omitted from the jury instructions, the factors for

determining whether there was a substantial risk of a

miscarriage of justice remain the focus of the analysis. The

factors applicable to circumstances where an element has been

omitted in particular, however, and the manner in which they

should be considered, are captured in the standard we

articulated in Azar: whether the presence of the omitted

element was an ineluctable inference from the evidence at trial.

See Azar, 435 Mass. at 687. This standard, although undoubtedly

high, is best understood as an explanation of the applicable

substantial risk factors, and not a deviation from their

application. Where an element of a crime is omitted from the

instructions, the jury are erroneously excused from applying the

facts, as they find them, to that element. This creates a risk

of conviction in circumstances where the Commonwealth failed to 4

meet its burden of proof beyond a reasonable doubt as to the

missing element. Our substantial risk of a miscarriage of

justice analysis in these circumstances thus must be

correspondingly exacting.

Because, in this case, the defendant's knowledge that the

coventurers were armed or masked cannot be ineluctably inferred

from the evidence at trial, the instructional error leaves us

with a serious doubt whether the result of the trial might have

been different had the jury been correctly instructed. We

therefore conclude that the error created a substantial risk of

a miscarriage of justice. As a result, we reduce the

defendant's convictions of armed robbery while masked to unarmed

robbery, and we vacate the judgment on the conviction of armed

home invasion and set aside the verdict.

Background. We recite the relevant facts adduced at trial

to establish the defendant's guilt as a coventurer.

1. The home invasion. On the evening of January 5, 2014,

the homeowner, his daughter, and her boyfriend, who was visiting

for the evening, were all in the home. The homeowner (victim)1

went to bed at approximately 9 P.M., as he did most nights,

after all the doors to his home were locked. Not long after

1 We recognize that the daughter and her boyfriend were also victims, but we refer to them by their relational titles to avoid confusion. 5

9 P.M., two masked men entered the home: a shorter, heavy-set

man with "Hispanic, African-American kind of complexion" and a

tall, Caucasian man.2 The taller man carried a gun, and the

shorter, heavier-set man carried a ten to twelve inch crowbar.

It is undisputed that neither man was the defendant.

The two men first entered the daughter's bedroom, where the

daughter and her boyfriend were watching television. The men

carried two zip ties. They tied the boyfriend's hands behind

his back with one of the zip ties, and then whispered to each

other. The daughter heard one say, "Just go duct tape her," and

the men proceeded to tie the daughter's hands behind her back

with duct tape. The men also placed duct tape over the mouths

of the daughter and her boyfriend. The men forced both to lie

on the floor and placed a blanket over their heads. They asked

the daughter where her father was, but they did not ask about

her mother, who was deceased.

The men next went to the victim's bedroom. The heavier-set

man jostled the victim awake and flipped him over in bed. He

tied the victim's hands behind his back with the second zip tie.

The men pulled the victim out of bed and pushed him down the

hallway toward the living room where there was a stone chimney.

2 The man with the darker complexion did not have his face fully covered by the mask, and while the lighter-complexioned man had a "full-fledged mask" on, the skin under his eyes was visible. 6

A picture that ordinarily hung on the chimney to hide a safe

that was installed there had already been removed. The safe was

exposed. At the taller gunman's insistence, the victim provided

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Johnson v. United States
520 U.S. 461 (Supreme Court, 1997)
Neder v. United States
527 U.S. 1 (Supreme Court, 1999)
Commonwealth v. Freeman
227 N.E.2d 3 (Massachusetts Supreme Judicial Court, 1967)
Commonwealth v. Fluellen
924 N.E.2d 713 (Massachusetts Supreme Judicial Court, 2010)
Commonwealth v. Russell
23 N.E.3d 867 (Massachusetts Supreme Judicial Court, 2015)
Commonwealth v. Horne
66 N.E.3d 633 (Massachusetts Supreme Judicial Court, 2017)
Commonwealth v. Phap Buth
101 N.E.3d 925 (Massachusetts Supreme Judicial Court, 2018)
Commonwealth v. Lutskov
106 N.E.3d 632 (Massachusetts Supreme Judicial Court, 2018)
Commonwealth v. Vizcarrondo
693 N.E.2d 677 (Massachusetts Supreme Judicial Court, 1998)
Commonwealth v. Alphas
712 N.E.2d 575 (Massachusetts Supreme Judicial Court, 1999)
Commonwealth v. LeFave
714 N.E.2d 805 (Massachusetts Supreme Judicial Court, 1999)
Commonwealth v. Vizcarrondo
727 N.E.2d 821 (Massachusetts Supreme Judicial Court, 2000)
Commonwealth v. Ellis
739 N.E.2d 1107 (Massachusetts Supreme Judicial Court, 2000)
Commonwealth v. Azar
760 N.E.2d 1224 (Massachusetts Supreme Judicial Court, 2002)
Commonwealth v. Randolph
780 N.E.2d 58 (Massachusetts Supreme Judicial Court, 2002)
Commonwealth v. Netto
783 N.E.2d 439 (Massachusetts Supreme Judicial Court, 2003)
Commonwealth v. Russell
787 N.E.2d 1039 (Massachusetts Supreme Judicial Court, 2003)
Commonwealth v. Azar
825 N.E.2d 999 (Massachusetts Supreme Judicial Court, 2005)
Commonwealth v. Dagraca
854 N.E.2d 1249 (Massachusetts Supreme Judicial Court, 2006)
Commonwealth v. Cannon
869 N.E.2d 594 (Massachusetts Supreme Judicial Court, 2007)

Cite This Page — Counsel Stack

Bluebook (online)
Commonwealth v. Desiderio, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-desiderio-mass-2023.