Commonwealth v. Gary E. Mosso

CourtMassachusetts Supreme Judicial Court
DecidedDecember 3, 2025
DocketSJC-13706
StatusPublished

This text of Commonwealth v. Gary E. Mosso (Commonwealth v. Gary E. Mosso) 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. Gary E. Mosso, (Mass. 2025).

Opinion

SUPREME JUDICIAL COURT

COMMONWEALTH vs. GARY E. MOSSO

Docket: SJC-13706
Dates: September 8, 2025 - December 3, 2025
Present: Budd, C.J., Gaziano, Kafker, Wendlandt, Georges, Dewar, & Wolohojian, JJ.
County: Worcester
Keywords: Homicide. Constitutional Law, Assistance of counsel, Plea. Practice, Criminal, Assistance of counsel, Plea, New trial

            Indictment found and returned in the Superior Court Department on March 8, 1984.

            Following review by this court, 399 Mass. 863 (1987), a motion for a new trial, filed on October 18, 2016, was heard by J. Gavin Reardon, Jr., J., and a motion for reconsideration was considered by him.

            A request for leave to appeal was allowed by Kafker, J., in the Supreme Judicial Court for the county of Suffolk.

            Paul R. Rudof (Michael Hussey also present) for the defendant.

            Donna-Marie Haran, Assistant District Attorney, for the Commonwealth.

            WOLOHOJIAN, J.  At issue is whether the defendant was deprived of his constitutional right to effective counsel when his attorney allegedly ignored his request to initiate plea negotiations with the prosecutor.  We conclude that a claim of ineffective assistance of counsel may be established where a defendant shows both that it was unreasonable in the circumstances for the attorney to ignore the defendant's request to explore the possibility of a plea bargain and that prejudice resulted from the attorney's failure to heed the defendant's reasonable request.  To establish prejudice in this context, the defendant must show that there was a reasonable probability the prosecutor would have accepted the plea offer the defendant requested his attorney to pursue, that there was a reasonable probability that the plea offer would have been presented to and accepted by the judge, and that the loss of the plea opportunity led to a trial resulting in a conviction of more serious charges or the imposition of a more severe sentence.  Here, accepting that the defendant instructed his trial counsel to explore with the prosecutor the possibility of pleading guilty to murder in the second degree and that such a plea was reasonable in the circumstances of this case, and further accepting that trial counsel ignored that instruction, we nonetheless discern no error in the denial of the defendant's motion for a new trial because the defendant failed to show a reasonable probability that the prosecutor would have entertained a stand-alone plea from the defendant in this multidefendant case.  We accordingly affirm the denial of the defendant's motion for a new trial.

            Background.  In 1984, the defendant and his codefendant were convicted, after a joint jury trial, of murder in the first degree by extreme atrocity or cruelty on a theory of joint venture for beating Anthony Tamburro to death.[1]  As a consequence of the verdict, the defendant received a mandatory sentence of life without the possibility of parole.  We affirmed both convictions after conducting plenary review under G. L. c. 278, § 33E.  See Commonwealth v. Sinnott, 399 Mass. 863, 884-885 (1987).

            More than twenty years later, the codefendant filed a motion for a new trial claiming that his attorney had provided ineffective assistance in connection with plea negotiations.  More specifically, the codefendant contended that he had instructed his attorney to "get a deal" before trial, and that the attorney had informed him that the prosecutor would not accept a plea to manslaughter.  He also claimed that the attorney never discussed with him prior to trial the differences between the various types of homicide or their sentencing consequences and options, and that he did not understand them.  The codefendant further claimed that had he been informed of those differences, he would have instructed his attorney to offer to plead guilty to murder in the second degree before trial, and that the offer would have been accepted by the prosecutor and the trial judge.  Finally, the codefendant claimed that, approximately two weeks into trial, his trial counsel suggested that he plead guilty to murder in the second degree, and the codefendant told the attorney to "make that happen."  Although the attorney then attempted to negotiate such a plea, the proposal was rejected by the prosecutor.  The trial then proceeded to its conclusion and, as we have already noted, the codefendant was convicted of murder in the first degree.

            The motion judge (who had not been the trial judge) denied the codefendant's motion for a new trial after an evidentiary hearing at which three witnesses testified:  the trial prosecutor, a respected member of the bar who testified as an expert, and the codefendant.  The judge did not credit the codefendant's testimony that his attorney had not informed him of the differences among the various forms of homicide or of their sentencing consequences.  The judge found that the prosecutor, given the facts and circumstances of the crime, was at all times unwilling to entertain a manslaughter plea.  And the judge also found that the prosecutor would not have considered a plea to murder in the second degree unless both the defendant and the codefendant agreed to it -- a circumstance that never existed.  The motion judge thus concluded that the codefendant's motion for a new trial was premised on "a substantial degree of speculation about what could have happened if [the defendant's] attorney had behaved differently and [the defendant] had also agreed to plead to second degree murder."  Concluding that speculation was an inadequate basis upon which to grant a new trial, the judge denied the codefendant's motion.

            After the codefendant had filed his motion for a new trial, the defendant filed the motion for a new trial that is at issue in this appeal.[2],[3]  Similarly to the codefendant, the defendant claimed that he had received ineffective assistance of counsel relating to plea negotiation.  However, the defendant's motion, as amplified by his testimony, differed in significant details from that of the codefendant.  Unlike the codefendant, the defendant acknowledged that he had an understanding of the differences between the forms of homicide.  He claimed that he had repeatedly asked his trial counsel (defense counsel) before trial to explore the possibility of pleading guilty to something less than murder in the first degree.  And he also claimed that he did not learn until 2016 that defense counsel had ignored his requests, or that the prosecutor had been willing to accept a plea to murder in the second degree if both the defendant and the codefendant agreed to it.

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