Commonwealth v. James M. O'neil.

CourtMassachusetts Appeals Court
DecidedMay 16, 2023
Docket22-P-0461
StatusUnpublished

This text of Commonwealth v. James M. O'neil. (Commonwealth v. James M. O'neil.) 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. James M. O'neil., (Mass. Ct. App. 2023).

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

22-P-461

COMMONWEALTH

vs.

JAMES M. O'NEIL.

MEMORANDUM AND ORDER PURSUANT TO RULE 23.0

In 1981, after a jury trial, the defendant was convicted of

two counts of rape of a child and two counts of indecent assault

and battery on a child under fourteen years of age. The sexual

assaults occurred in 1978, and the victims, D.R. and R.W., were

eleven and twelve year old boys at the time. On direct appeal,

this court affirmed the defendant's convictions in Commonwealth

v. O'Neil, 14 Mass. App. Ct. 978 (1982). The defendant's first

motion for new trial was denied without an evidentiary hearing

in 1985. In 2020, the defendant filed a second motion for new

trial, the motion judge held an evidentiary hearing, and later

denied the motion in a thoughtful and comprehensive memorandum.

The judge subsequently denied the defendant's motion to

reconsider the denial. On appeal, the defendant raises a variety of claims concerning the denial of the new trial motion.1

We affirm.

Discussion. 1. Victims' 2006 statements. The defendant

claims that he is entitled to a new trial based on claimed newly

discovered evidence that the victims, nearly three decades after

their sexual assaults, purportedly recanted their identification

of the defendant as the man who raped them. We disagree.

"A defendant seeking a new trial on the ground of newly

discovered evidence must establish both that the evidence is

newly discovered and that it casts real doubt on the justice of

the conviction." Commonwealth v. Domino, 465 Mass. 569, 582

(2013), quoting Commonwealth v. Grace, 397 Mass. 303, 305

(1986). The defendant "also bears the burden of demonstrating

that any newly discovered evidence is admissible." Commonwealth

v. Weichell, 446 Mass. 785, 799 (2006). "In considering a

motion for a new trial based on newly discovered evidence, it

[is] [within] the judge's discretion to determine the weight and

import of affidavits submitted . . . The abuse of discretion

standard is not altered when the newly discovered evidence is an

alleged recantation by a material witness" (citation omitted).

1 The defendant's separate appeals from the orders denying his motions for new trial and to reconsider were consolidated for briefing and decision. The defendant failed to address any aspect of the memorandum and order on the latter motion, waiving that appeal.

2 Domino, supra. "In such circumstances, 'the duty of the trial

judge is to give grave consideration to the credibility of the

witness's new testimony.'" Id. at 582-583, quoting Commonwealth

v. Robertson, 357 Mass. 559, 562 (1970).

Here, the claimed newly discovered evidence is the two

victims' 2006 purported recantations made to the defendant's

private investigator, John Ahern. In the most generous light,

these statements call into question whether the victims had

properly identified the defendant as their rapist.2 But it is

difficult to conclude that these statements are newly discovered

evidence. "Newly discovered evidence is evidence that was

unknown to the defendant or counsel and not reasonably

discoverable by them at the time of trial." Commonwealth v.

Sullivan, 469 Mass. 340, 350 n.6 (2014), citing Grace, 397 Mass.

at 306. As both victims were available to the defendant at

trial, and both were cross-examined, the reliability or accuracy

of their identification of the defendant was reasonably

discoverable at trial. See Grace, supra ("The defendant has the

2 As the motion judge found, what the victims purportedly told Ahern was not entirely exculpatory. In fact, R.W. maintained that the defendant may well have been the perpetrator, and D.R. never said that he was not, despite language in Ahern's report suggesting otherwise. However, at trial, R.W. testified that, when he saw the defendant during the showup identification procedure, there was no doubt in his mind that the defendant was the person who had raped him. D.R. testified that during the showup, he noted the defendant's distinctive teeth and voice, and recalled: "I said that was definitely him."

3 burden of proving that reasonable pretrial diligence would not

have uncovered the evidence"). In any event, the proper denial

of the motion for new trial does not turn on this issue, and we

will assume the evidence was newly discovered.

Even if the evidence was newly discovered, it was still the

defendant's burden to establish that the motion judge abused his

discretion by concluding that it would not have cast real doubt

on the justice of the defendant's convictions. See Grace, 390

Mass. at 305-307; Commonwealth v. Coutu, 88 Mass. App. Ct. 686,

700 (2015). The first hurdle for the defendant in carrying this

burden was that, as the motion judge properly found, the

evidence was not admissible. As the motion judge determined,

and the defendant conceded in his memorandum in support of his

motion for new trial, the statements Ahern attributed to the

victims are inadmissible hearsay. Despite his concession, the

defendant claims these statements would be admissible under the

exception to the hearsay rule articulated in Commonwealth v.

Drayton, 473 Mass. 23, 40 (2015). We disagree.

In Drayton, the Supreme Judicial Court noted that in "the

vast majority of cases, the established hearsay exceptions will

continue to govern the admissibility of hearsay evidence at most

criminal trials," but a "constitutional hearsay exception" might

operate "in the rarest of cases, where otherwise inadmissible

evidence is both truly critical to the defense's case and bears

4 persuasive guarantees of trustworthiness." Drayton, 473 Mass.

at 40. At issue in Drayton was a statement that was contained

in an affidavit that directly contradicted the testimony of a

key witness for the prosecution, who claimed to have witnessed

the crime. Id. at 24. The court concluded that the affidavit

was "critical to the defense," but that a remand was required to

determine whether the affidavit bore "persuasive assurances of

trustworthiness." Id. at 36.

In this case, as noted above, the victim's statements are

not directly contradictory to any of the trial testimony as were

the statements recited in an affidavit in Drayton. But even if

they were, as the motion judge found, the statements do not bear

persuasive guarantees of trustworthiness. Ahern failed to have

either victim sign an affidavit, and both had died before the

evidentiary hearing was conducted in 2020. When D.R. spoke with

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Commonwealth v. James M. O'neil., Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-james-m-oneil-massappct-2023.