Commonwealth v. John C. Ramirez.

CourtMassachusetts Appeals Court
DecidedJuly 14, 2025
Docket23-P-1241
StatusUnpublished

This text of Commonwealth v. John C. Ramirez. (Commonwealth v. John C. Ramirez.) 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. John C. Ramirez., (Mass. Ct. App. 2025).

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-1241

COMMONWEALTH

vs.

JOHN C. RAMIREZ.

MEMORANDUM AND ORDER PURSUANT TO RULE 23.0

Following a bench trial in the District Court, the

defendant was found guilty of assault and battery on a family or

household member in violation of G. L. c. 265, § 13M (a). The

sole issue raised on appeal is whether trial counsel rendered

ineffective assistance in posing a question to the victim that

elicited testimony establishing the location of the offense.

The defendant argues that without this testimony, the

Commonwealth could not prove that the court had territorial

jurisdiction and, consequently, he was deprived of a substantial

ground of defense. We affirm.

Background. The Commonwealth presented its case through

two witnesses, Sergeant William Mears and the victim. On the basis of their testimony, the judge could have found the

following facts. On May 24, 2021, in the early evening, the

victim went to the Haverhill police station with her mother and

a friend to report that she had been beaten by her boyfriend,

John Ramirez. Sergeant Mears, a Haverhill police officer, was

working a 4:30 P.M. to 12:30 A.M. shift and spoke with the

victim at around six or seven o'clock. He described the victim

as "visibly shaken" and observed bruises on her cheeks and arms.1

The victim told Sergeant Mears that she lived on Presidential

Drive. The incident occurred in her apartment where she and the

defendant lived with the victim's three children. At some point

thereafter, Sergeant Mears dispatched officers to an address the

victim provided to look for the defendant. There was no

testimony specifying the location of that address and, as it

turned out, the defendant was not found there.

At the time of trial, the victim was no longer in a

relationship with the defendant. She testified that she had

been dating the defendant for about four to five years when, on

Sunday, May 23, (the day before she went to the police station),

she and the defendant had an argument over money. The argument

escalated and the defendant pushed the victim out of her chair.

1 The victim's injuries were photographed by a different officer and the photographs were introduced at trial.

2 The victim fell to the floor after which the defendant "stomped"

on her and beat her with both open and closed fists. The victim

managed to escape to the bathroom where she waited until things

calmed down. When she emerged, the defendant told her that he

loved her and that "it wouldn't happen again." Then, the two

went to take a walk at "the stadium."

On cross-examination, the victim clarified that the

defendant drove to the stadium and that her daughter accompanied

them. Then, in response to the following question posed by

counsel: "[d]o you know the name of the stadium?" the victim

stated: "[t]he stadium. That's what it's called, in

Haverhill." The victim later described the stadium as "a big

park" and again stated it was in Haverhill.

Discussion. The defendant argues for the first time on

appeal that the only evidence that established the location of

the offense was solicited by defense counsel when he asked the

victim for the name of the stadium to which she replied

"Haverhill." Although he acknowledges that location is not an

element of the offense, see Commonwealth v. Gray, 85 Mass. App.

Ct. 85, 87 (2014), the defendant asserts that without the

victim's response, the Commonwealth failed to prove that the

criminal act occurred in Massachusetts and, as a result, did not

show that the court had jurisdiction over him. See Commonwealth

3 v. Combs, 480 Mass. 55, 60 (2018), quoting Commonwealth v.

Fleming, 360 Mass. 404, 406 (1971) ("[i]t is elementary that it

must be shown that jurisdiction lodged in the courts of

Massachusetts before the defendant can be found guilty of the

offense charge"). According to the defendant, counsel provided

ineffective assistance of counsel because, but for the testimony

at issue, he could have filed a successful motion for a required

finding of not guilty on the ground that the court lacked

territorial jurisdiction.

As an initial matter, because the defendant did not raise

his claim of ineffective assistance in a motion for new trial,

we must first decide whether the factual basis of the claim

appears indisputably on the record. See Commonwealth v. Keon

K., 70 Mass. App. Ct. 568, 573-574 (2007) ("[o]ur courts

strongly disfavor raising claims of ineffective assistance on

direct appeal. A claim of ineffective assistance of counsel

should only be brought on direct appeal when . . . the issues do

not implicate any factual questions more appropriately resolved

by a trial judge" [quotation and citation omitted]). The claim

raised here is sufficiently developed on the record and we

therefore conclude that it is appropriate for us to resolve in

the first instance the question of whether the defendant

received ineffective assistance.

4 We now turn to the merits of the defendant's argument. In

order to prevail, the defendant must meet his burden under the

familiar two-pronged test set forth in Commonwealth v. Saferian,

366 Mass. 89, 96 (1974). He must show that (1) counsel's

conduct fell "measurably below that which might be expected from

an ordinary fallible lawyer" and (2) the conduct "likely

deprived the defendant of an otherwise available, substantial

ground of defen[s]e." Id. The defendant has not met his burden

on either prong.

First, we recognize that in some circumstances, our case

law has treated territorial jurisdiction as an element of the

offense. See Combs, 480 Mass. at 56; Fleming, 360 Mass. at 406.

In those cases, however, the question of territorial

jurisdiction was a triable issue or had been put into issue by

the defendant. Where, as here, it was not reasonable to assume

the offense was committed outside the boundaries of the

Commonwealth, an "ordinary fallible lawyer" would not have been

concerned about soliciting testimony regarding the location of

the offense.2 Indeed, the criminal complaint, of which the

defendant had a copy, specifies the location of the offense as

2 Additionally, as the Commonwealth notes in its brief, the challenged testimony merely revealed where the victim went with the defendant after the incident, rather than the location of the incident itself.

5 "Haverhill." In addition, the crime was investigated by the

Haverhill police department which has no jurisdiction beyond the

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Related

Commonwealth v. Saferian
315 N.E.2d 878 (Massachusetts Supreme Judicial Court, 1974)
Commonwealth v. Fleming
274 N.E.2d 809 (Massachusetts Supreme Judicial Court, 1971)
Commonwealth v. Combs
100 N.E.3d 730 (Massachusetts Supreme Judicial Court, 2018)
Commonwealth v. Keon K.
875 N.E.2d 498 (Massachusetts Appeals Court, 2007)
Chace v. Curran
881 N.E.2d 792 (Massachusetts Appeals Court, 2008)
Commonwealth v. Gray
5 N.E.3d 1242 (Massachusetts Appeals Court, 2014)

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Commonwealth v. John C. Ramirez., Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-john-c-ramirez-massappct-2025.