Commonwealth v. Francisco Nunez Severino.

CourtMassachusetts Appeals Court
DecidedOctober 15, 2025
Docket24-P-1211
StatusPublished

This text of Commonwealth v. Francisco Nunez Severino. (Commonwealth v. Francisco Nunez Severino.) 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. Francisco Nunez Severino., (Mass. Ct. App. 2025).

Opinion

APPEALS COURT

COMMONWEALTH vs. FRANCISCO NUNEZ SEVERINO.[1]

Docket: 24-P-1211
Dates: June 6, 2025 – October 15, 2025
Present: Englander, Toone, & Wood, JJ.
County: Essex
Keywords: Firearms. License. Evidence, Joint venturer, Firearm, Constructive possession, Spontaneous utterance. Constitutional Law, Right to bear arms, Double jeopardy. Practice, Criminal, Instructions to jury, Double jeopardy.

            Indictments found and returned in the Superior Court Department on December 8, 2021.

            The cases were tried before Janice W. Howe, J.

            Edward Crane for the defendant.

            Kathryn L. Janssen, Assistant District Attorney, for the Commonwealth.

            ENGLANDER, J.  This case asks us to determine, in light of the Supreme Judicial Court's two decisions in Commonwealth v. Guardado, 491 Mass. 666 (2023) (Guardado I), same case, 493 Mass. 1 (2023) (Guardado II), cert. denied, 144 S. Ct. 2683 (2024), whether proof of a coventurer's lack of license is an essential element of joint venture liability for a firearms possession offense, where the coventurer is the person seen in possession of the firearm.  The charges in this case arose out of two shootings that occurred in August of 2021.  The defendant, Francisco Nunez Severino, and a second person (referred to as Doe) were present at a party in a Lawrence apartment when a fight broke out.  The defendant and Doe left the party in the defendant's car, but the defendant later drove Doe back to the apartment building.  Doe exited the car brandishing a gun, walked up to the apartment, and fired a shot through the apartment door.  Fifteen minutes later, one of the partygoers returned to his van parked outside.  The defendant thereafter drove alongside the van, and Doe exited the defendant's car and shot at the van.  The defendant was later arrested near the apartment; neither Doe, nor the gun, were with him.

            The defendant was charged with multiple offenses, including carrying a firearm without a license and carrying a loaded firearm without a license (as well as various assault charges).  At the defendant's trial in June of 2023, which occurred after Guardado I, the judge instructed the jury that the defendant could be found guilty of possession of a firearm without a license if the defendant "knowingly participated in the commission of the crime[s] charged alone or with others with the intent required for that offense."  The judge did not, however, instruct the jury that to convict the defendant as a joint venturer, the jury needed to find that Doe lacked a license.  The judge also instructed the jury that it could find the defendant guilty on a theory that he (the defendant) was in constructive possession of the firearm.  The judge instructed the jury that it was an element of the offense that the defendant did not have a license, and evidence was introduced (by stipulation) that he did not. 

            The defendant now argues that the judge's instruction on the joint venture firearm possession charges were erroneous because she left out a required element -- that the jury needed to find that Doe lacked a license -- and that this error created a substantial risk of a miscarriage of justice.  The defendant also argues that a 911 call made by an occupant of the apartment was improperly admitted as an excited utterance, and that such admission constituted prejudicial error requiring reversal of his convictions arising from the first shooting.

            The Commonwealth concedes that the jury instruction was erroneous as to the firearm possession charge, where the Commonwealth proceeded under a joint venture theory.  The Commonwealth disagrees with the defendant, however, as to the proper remedy for this error.  Both parties contend that we should separately analyze the sufficiency of the evidence for the joint venture theory and the constructive possession theory.  The Commonwealth argues that there was sufficient evidence that the defendant constructively possessed the firearm, and that on that basis the defendant's convictions may be affirmed.  The defendant argues that at the least a new trial is required, and also that he may not be retried on a joint venture theory because, the defendant argues, there was insufficient evidence as to that theory due to the failure to prove that Doe did not have a license.

            We agree with the parties that the jury instructions were erroneous.  When a jury is instructed on aiding and abetting for a firearms possession offense,[2] the jury must also be instructed that an essential element of the defendant's aiding and abetting/joint venture liability is that the coventurer (who was in actual or constructive possession of the firearm) lacked a license.  Where, as here, there was an error in the instruction, a new trial is in order, at which the defendant may be retried only on the theory or theories for which there was sufficient evidence at the first trial.  In the present case, the evidence as to joint venture was insufficient, because the Commonwealth did not show that the coventurer was unlicensed.  We further conclude that at the time of trial (after Guardado I but before Guardado II), the Commonwealth reasonably should have known that it had to prove that Doe lacked a license for the defendant to be guilty of aiding and abetting a firearm possession offense, and thus the defendant may not be retried on the joint venture theory.  Furthermore, the evidence as to principal liability (constructive possession by the defendant) was also insufficient, and thus the defendant may not be retried on that theory either.  As we discern no error in the admission of the 911 call, we affirm the defendant's remaining convictions.

            Background.  Based on the evidence at trial, the jury could reasonably have found the following.  During the morning of August 29, 2021, the defendant and Doe were present at a party in a fourth-floor apartment in Lawrence.  R.M.,[3] one of the eventual victims, arrived at the party while it was in progress.  At some point thereafter, the defendant and Doe pulled out police badges.  Later, an argument among some of the partygoers ensued, and the defendant and Doe left. 

            There were multiple surveillance cameras recording the area around the apartment building; video recordings of relevant events around both shootings were in evidence.  On one surveillance video, one can see Doe running away from the apartment building at 8:32 A.M.  At 8:33 A.M., the defendant exited the building, and a black SUV pulled up to the apartment building and picked up the defendant; the SUV then drove away. 

            Subsequently, at 8:45 A.M., the SUV returned.  Doe exited from the passenger side, holding a gun, and entered the apartment building.  The gun is clearly visible in the surveillance video.  As Doe entered the building, the SUV drove away. 

            Grand jury testimony from R.M. was introduced that Doe walked up the stairs to the apartment, concealing the gun as he approached.  R.M. was then leaving the party, and saw Doe's gun.  R.M.

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Commonwealth v. Francisco Nunez Severino., Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-francisco-nunez-severino-massappct-2025.