Commonwealth v. Jeffrey Hanson.

CourtMassachusetts Appeals Court
DecidedDecember 24, 2024
Docket24-P-0030
StatusUnpublished

This text of Commonwealth v. Jeffrey Hanson. (Commonwealth v. Jeffrey Hanson.) 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. Jeffrey Hanson., (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

24-P-30

COMMONWEALTH

vs.

JEFFREY HANSON.

MEMORANDUM AND ORDER PURSUANT TO RULE 23.0

After a jury trial, the defendant was convicted of two

counts of aggravated rape of a child under the age of sixteen,1

and one count of incest. On appeal, he claims the first

complaint witness's testimony about the investigative process

was irrelevant and prejudicial, the evidence of the defendant's

past drug use was improper character and bad act evidence, and

the prosecutor's closing argument improperly appealed to the

jury's sympathy and vouched for the victim's and a witness's

credibility. We affirm.

1The aggravating factor was the more than five-year difference in the ages of the defendant and victim, who was under twelve years old. See G. L. c. 265, § 23A (a). 1. First complaint testimony. At the time of the

offenses, the victim was five years old. The victim's mother

was the first complaint witness. For the first time on appeal,

the defendant claims that the mother's testimony regarding what

she did in the aftermath of the victim's disclosure violated the

first complaint rule. In particular, the defendant takes issue

with the mother's testimony that she: (1) contacted the

victim's pediatrician; (2) met with a social worker who assisted

her with reporting the matter to the Department of Children and

Families; and (3) reported the assaults to the police. None of

these claims were preserved by an objection at trial, so we

review to determine whether this evidence created a substantial

risk of a miscarriage of justice. See Commonwealth v. Freeman,

352 Mass. 556, 563–564 (1967).

In Commonwealth v. King, 445 Mass. 217, 246-247 (2005),

cert. denied, 546 U.S. 1216 (2006), the Supreme Judicial Court

announced the first complaint rule, and explained its purpose as

follows:

"[t]he goal of this new first complaint doctrine is to give the jury as complete a picture as possible of how the accusation of sexual assault first arose. That complete picture will allow them to make a fairer and more accurate assessment of the validity of that accusation, based on specific information about the people involved rather than on outdated stereotypes and generalities."

2 Indeed, "a first complaint witness may testify to the

circumstances surrounding the initial complaint." Id. at 246.

Moreover, "[f]irst complaint testimony, including the details

and circumstances of the complaint, will be considered

presumptively relevant to a [victim's] credibility in most

sexual assault cases where the fact of the assault or the issue

of consent is contested." Id. at 247.

Here, the mother's testimony regarding the steps she took

following the victim's disclosure did not violate the first

complaint rule because it was relevant to the circumstances of

the complaint, and it tended to negate the defense theory of

fabrication.2 The mother's testimony about her reactions and the

steps she took were relevant to whether she had influenced the

victim, or manufactured the allegations. See Commonwealth v.

McCoy, 456 Mass. 838, 845 (2010), quoting King, 445 Mass. at 246

(first complaint witness may testify to "other relevant

conditions that might help a jury assess the veracity of the

[victim's] allegations or assess the specific defense theories

as to why the [victim] is making a false allegation").

2 The defense maintained that the defendant never sexually assaulted the victim, and that the allegations were entirely fabricated by the victim's mother, who the defense claimed "hated" the defendant.

3 To the extent this evidence touched on matters that

preceded an investigation, it was not an improper introduction

of how the Commonwealth brought its resources to bear on the

incident, Commonwealth v. Stuckich, 450 Mass. 449, 457 (2008).

Rather, it was a proper response to the theory of defense, see

Commonwealth v. Espinal, 482 Mass. 190, 202 (2019); Commonwealth

v. Santos, 465 Mass. 689, 700-701 (2013), particularly in this

case with a child victim. See King, 445 Mass. at 239-240. The

admission of the mother's first complaint testimony, including

that now complained of, provided the jury with information that

permitted them to make a fair assessment of the victim's

credibility. See Commonwealth v. Hartnett, 72 Mass. App. Ct.

467, 472 (2008). There was no error, and thus, no risk that

justice miscarried. See Commonwealth v. Randolph, 438 Mass.

290, 297 (2002).

2. The defendant's past drug use. The defendant also

claims that the admission of evidence of his past drug use was

improper character and bad act evidence which resulted in

prejudicial error. We disagree.

Prior to trial, the defendant moved in limine to prohibit

the Commonwealth's witnesses from testifying relative to, among

other things, the defendant's past sale or use of drugs. At the

hearing on the motion, the prosecutor agreed that he would not

4 introduce such evidence in his case-in-chief, but expressed

concern that he not be subject to the same limitation if defense

counsel opened the door to its admission. Ultimately, the judge

ruled that if the defense opened the door, the prosecutor would

be required to seek the judge's permission before pursuing the

matter.

At trial, the prosecutor heeded the evidentiary limitation

and did not introduce any evidence of the defendant's past drug

use in his direct examination of the witnesses. The

Commonwealth called the defendant's brother as a prosecution

witness. He testified that after the defendant was arrested on

the charges at issue here, the defendant asked him to meet; at

the meeting, the defendant admitted to having abused the victim

as she described. On cross-examination of the defendant's

brother, defense counsel asked whether he had drifted apart from

the defendant over the past couple of years, and he replied that

he now only got together with the defendant "reluctantly" a few

times a year. On redirect, the prosecutor asked why the two had

drifted apart, and the brother responded, "Part of it is this

issue, I think, . . . he has a drug problem, and I don't want

that around my -- my family."3 The defendant did not object.

3 Although the prosecutor did not seek a sidebar conference before asking this question, it is not clear, on this record,

5 As an initial matter, the parties disagree on whether the

motion in limine preserved the defendant's claim. We need not

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

Related

Commonwealth v. Foster
585 N.E.2d 331 (Massachusetts Supreme Judicial Court, 1992)
Commonwealth v. Carrion
552 N.E.2d 558 (Massachusetts Supreme Judicial Court, 1990)
Commonwealth v. Freeman
227 N.E.2d 3 (Massachusetts Supreme Judicial Court, 1967)
Commonwealth v. McCowen
939 N.E.2d 735 (Massachusetts Supreme Judicial Court, 2010)
Commonwealth v. McCoy
926 N.E.2d 1143 (Massachusetts Supreme Judicial Court, 2010)
Commonwealth v. Garcia
18 N.E.3d 654 (Massachusetts Supreme Judicial Court, 2014)
Commonwealth v. Dirgo
52 N.E.3d 160 (Massachusetts Supreme Judicial Court, 2016)
Commonwealth v. Grady
54 N.E.3d 22 (Massachusetts Supreme Judicial Court, 2016)
Commonwealth v. Espinal
121 N.E.3d 1189 (Massachusetts Supreme Judicial Court, 2019)
Commonwealth v. Raymond
676 N.E.2d 824 (Massachusetts Supreme Judicial Court, 1997)
Commonwealth v. Freeman
712 N.E.2d 1135 (Massachusetts Supreme Judicial Court, 1999)
Commonwealth v. Randolph
780 N.E.2d 58 (Massachusetts Supreme Judicial Court, 2002)
Commonwealth v. Daley
789 N.E.2d 1070 (Massachusetts Supreme Judicial Court, 2003)
Commonwealth v. King
834 N.E.2d 1175 (Massachusetts Supreme Judicial Court, 2005)
Commonwealth v. Dwyer
859 N.E.2d 400 (Massachusetts Supreme Judicial Court, 2006)
Commonwealth v. Rebello
876 N.E.2d 851 (Massachusetts Supreme Judicial Court, 2007)
Commonwealth v. Stuckich
879 N.E.2d 105 (Massachusetts Supreme Judicial Court, 2008)
Commonwealth v. Santos
991 N.E.2d 1049 (Massachusetts Supreme Judicial Court, 2013)
Commonwealth v. Deloney
794 N.E.2d 613 (Massachusetts Appeals Court, 2003)
Chace v. Curran
881 N.E.2d 792 (Massachusetts Appeals Court, 2008)

Cite This Page — Counsel Stack

Bluebook (online)
Commonwealth v. Jeffrey Hanson., Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-jeffrey-hanson-massappct-2024.