COMMONWEALTH v. HAKIM H., a Juvenile.

CourtMassachusetts Appeals Court
DecidedMarch 19, 2024
Docket23-P-0212
StatusUnpublished

This text of COMMONWEALTH v. HAKIM H., a Juvenile. (COMMONWEALTH v. HAKIM H., a Juvenile.) 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. HAKIM H., a Juvenile., (Mass. Ct. App. 2024).

Opinion

NOTICE: Summary decisions issued by the Appeals Court pursuant to M.A.C. Rule 23.0, as appearing in 97 Mass. App. Ct. 1017 (2020) (formerly known as rule 1:28, as amended by 73 Mass. App. Ct. 1001 [2009]), are primarily directed to the parties and, therefore, may not fully address the facts of the case or the panel's decisional rationale. Moreover, such decisions are not circulated to the entire court and, therefore, represent only the views of the panel that decided the case. A summary decision pursuant to rule 23.0 or rule 1:28 issued after February 25, 2008, may be cited for its persuasive value but, because of the limitations noted above, not as binding precedent. See Chace v. Curran, 71 Mass. App. Ct. 258, 260 n.4 (2008).

COMMONWEALTH OF MASSACHUSETTS

APPEALS COURT

23-P-212

COMMONWEALTH

vs.

HAKIM H., a juvenile.

MEMORANDUM AND ORDER PURSUANT TO RULE 23.0

The appellant juvenile was adjudicated delinquent on a

complaint charging rape, in violation of G. L. c. 265, § 22 (b),

and indecent assault and battery on a person fourteen years old

or older, in violation of G. L. c. 265, § 13H. On appeal, the

juvenile claims that the adjudication of delinquency should be

reversed because of errors surrounding the admission of evidence

concerning an examination of the victim conducted by a Sexual

Assault Nurse Examiner (SANE). We affirm.

Background. The victim underwent a SANE examination a few

hours after reporting that the juvenile had raped her. The

nurse who examined the victim testified about her findings and

the forms she completed. Because the Commonwealth had

previously agreed to the juvenile's motion in limine not to

permit the nurse to give the impression that SANE nurses are "only brought in when there was a sexual assault," the

prosecutor and the nurse were careful to describe the medical

examination as a "forensic medical examination" rather than a

"sexual assault" examination, and to refer to the victim as the

"patient."

Forms that the nurse completed during the examination were

admitted in evidence. The words "sexual assault," "assault,"

and "sexual crime" were redacted from the titles of all the

forms; however, the parties failed to redact the words "assault"

and "assailant" in several places.

Sections of SANE forms 2A and 2B ask the examiner to check

boxes, based on the patient's report or the examiner's physical

findings, under the category "weapon/force used." On both forms

the nurse checked the box for "hold down/body weight." Form 2B

included a space for additional description, where the nurse

wrote "woke to person on top." Regarding this section of the

form, the prosecutor asked the nurse, "What, if anything, did

[the victim] describe?" The nurse answered, "[She] described

being held down."

Discussion. 1. Failure to redact. The juvenile claims

that it was reversible error to admit the SANE forms in evidence

without redacting the words "assault" and "assailant." See

Commonwealth v. Dargon, 457 Mass. 387, 396 (2010). The

Commonwealth agrees. The parties disagree, however, as to

2 whether the juvenile objected and, accordingly, the standard of

review.

The juvenile's counsel objected when the Commonwealth

requested that the SANE forms be marked as an exhibit. It is

not clear what the objection was. It appears that counsel

objected to only one portion of the exhibit, and that the

objection had to do with content that was unrelated to medical

treatment.1 "Because the [juvenile's] objections at trial went

to the substance of the victim's . . . statements [on the

forms], and the error here stemmed not from admission of those

statements, but rather from the failure to redact the language

of [the form] itself, we review for substantial risk of

miscarriage of justice." Dargon, 457 Mass. at 397.

We discern no such risk, because we are confident that in

the context of the entire trial, the failure to redact did not

materially influence the verdict. See id. at 397-398. See

Commonwealth v. Randolph, 438 Mass. 290, 298 (2002). The case

turned on whether the victim consented to the juvenile's

indecent touching and penetrating her. She testified that she

woke from a heavy sleep and felt the juvenile's penis in her

vagina. He testified that the victim was awake and willing when

1 Indeed, in his brief the juvenile states that he "objected to the forms coming in that do not go to treatment but to evidence collection."

3 he inserted his finger in her vagina and licked her vagina and

between her buttocks, and that she did not object until he

touched the tip of his penis to her "general butt area." In his

statements to his friends, however, he said he thought he had

"raped" the victim (although he claimed at trial that he "didn't

have a value of what that word actually meant in that time" and

that "[t]he word meant nothing at the time"). His oral and

written statements to the police suggested that the victim was

asleep and unresponsive. In closing argument, the prosecutor

focused on the testimony of the victim, of the victim's and

juvenile's friends, and on the juvenile's admissions. The

prosecutor mentioned the SANE report only once, in reference to

the tearing and bleeding of the victim's hymen. See Dargon, 457

Mass. at 398 (in closing argument prosecutor referenced only

admissible portions of SANE forms). We are confident that the

preprinted references to "assault" and "assailant" on the forms

had little, if any, influence on the jury's assessment of the

victim's lack of consent.

2. Descriptions of victim being held down. The checkmarks

on the forms for "hold down/body weight" and the victim's

description that she "woke to person on top" were properly

admitted under the medical records exception to the hearsay

rule. See G. L. c. 233, § 79; Mass. G. Evid. § 803(6)(B)

(2023). "The statute has long been construed to permit the

4 admission of a record that relates directly and primarily to the

treatment and medical history of the patient, 'even though

incidentally the facts recorded may have some bearing on the

question of liability.'" Commonwealth v. Torres, 479 Mass. 641,

653 (2018), quoting Commonwealth v. Dube, 413 Mass. 570, 573

(1992). The exception extends to "physical observations from

which inculpatory inferences flow" (quotation and citation

omitted). Commonwealth v. DiMonte, 427 Mass. 233, 242 (1998).

See, e.g., Commonwealth v. McGann, 484 Mass. 312, 319-320 (2020)

(statement "repeatedly beat him about the head/face and bit him

several times in arms and also came after him with steak knife"

in victim's medical records properly admitted). The fact that

SANE records have the "dual purpose" of medical treatment and

criminal investigation does not make them inadmissible. See

Dargon, 457 Mass. at 393, 395-396.

The defendant argues, for the first time on appeal, that

these notations of the forms are nonetheless inadmissible under

a free-standing notion of "reliability" that he derives from

Bouchie v. Murray, 376 Mass. 524, 528 (1978) ("the medical

records exception statute makes admissible only those portions

of records relating to treatment and medical history which

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Related

Bouchie v. Murray
381 N.E.2d 1295 (Massachusetts Supreme Judicial Court, 1978)
Commonwealth v. Dube
601 N.E.2d 467 (Massachusetts Supreme Judicial Court, 1992)
Commonwealth v. Dargon
930 N.E.2d 707 (Massachusetts Supreme Judicial Court, 2010)
Commonwealth v. Torres
98 N.E.3d 155 (Massachusetts Supreme Judicial Court, 2018)
Commonwealth v. DiMonte
692 N.E.2d 45 (Massachusetts Supreme Judicial Court, 1998)
Commonwealth v. Randolph
780 N.E.2d 58 (Massachusetts Supreme Judicial Court, 2002)
Commonwealth v. Vallejo
914 N.E.2d 22 (Massachusetts Supreme Judicial Court, 2009)
Chace v. Curran
881 N.E.2d 792 (Massachusetts Appeals Court, 2008)

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COMMONWEALTH v. HAKIM H., a Juvenile., Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-hakim-h-a-juvenile-massappct-2024.