Commonwealth v. Jorge A. Castillo.

CourtMassachusetts Appeals Court
DecidedNovember 20, 2025
Docket24-P-0341
StatusUnpublished

This text of Commonwealth v. Jorge A. Castillo. (Commonwealth v. Jorge A. Castillo.) 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. Jorge A. Castillo., (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

24-P-341

COMMONWEALTH

vs.

JORGE A. CASTILLO.

MEMORANDUM AND ORDER PURSUANT TO RULE 23.0

Following a jury trial in the Superior Court, the

defendant, Jorge A. Castillo, was convicted of five counts of

indecent assault and battery on a child under fourteen, in

violation of G. L. c. 265, § 13B, and intimidation of a witness,

in violation of G. L. c. 268, § 13B.1 On appeal, the defendant

claims that the judge abused his discretion by permitting the

victim to testify that the defendant had abused her on multiple

1The defendant was acquitted on one additional charge of indecent assault and battery on a child under fourteen. The defendant was also charged with two counts of aggravated rape and abuse of a child, in violation of G. L. c. 265, § 23A (a), and one count of open and gross behavior in violation of G. L. c. 272, § 16. The jury could not reach a verdict as to those charges, and the judge declared a mistrial as to each of them. After the defendant was convicted and sentenced, the Commonwealth filed a nolle prosequi as to those charges. prior occasions, and that the prosecutor's closing argument

exceeded the bounds of proper argument. We affirm.

Background. We summarize the facts the jury could have

found and reserve certain details for later discussion. From

2013 to 2015, the defendant's girlfriend babysat for her aunt's

children, the two victims whom we shall call J.S. and C.S., once

or twice a week at the home she shared with the defendant. J.S.

was between ten and twelve years old during this time, and C.S.

was between eleven and thirteen.

On one occasion, J.S. was at the defendant's home when she

came in from playing outside to get something from the kitchen.

While she stood at the refrigerator, the defendant came up from

behind her and touched her vaginal area over her clothing. J.S.

said she should go back outside, and the defendant told her not

to tell anyone in her family. J.S. agreed and walked out. On

three other occasions, the defendant sexually assaulted J.S.

when they were alone in the master bedroom of the home. Once,

the defendant touched J.S.'s breasts while forcing his penis

into her mouth while she sat on a "baby bed." On another

occasion, the defendant sat down on his bed and put his penis in

J.S.'s mouth. And another time, J.S. stood next to the

defendant as he made her touch his penis before he masturbated

next to her. Each time J.S. left the bedroom, the defendant

told her not to tell anyone in her family.

2 During the same time period, J.S. accompanied the defendant

when he drove to pick up his son from soccer practice. On the

way, the defendant pulled the car into a parking lot, parked,

and, while she sat in the passenger seat, touched J.S.'s vagina

and forced her to touch his penis. Again, the defendant told

J.S. not to tell anyone.

At some point, J.S. told her younger sister, C.S., how the

defendant had touched her, and the two agreed that they would

not leave each other alone with the defendant going forward.2 A

few years later, when she was fifteen, J.S. told her mother and

father and asked them not to inform the police about the abuse,

and they agreed not to do so.

Two years later, when J.S. was seventeen, she reported the

abuse to the police herself. This disclosure followed a party

at J.S.'s parents' home, where a guest's dog bit the defendant's

daughter. The defendant was not at the party, but after

learning what happened, he drove to J.S.'s parents' home and

told them that he was going to call the police. An argument

ensued, and as noted, J.S. told the police about the defendant's

conduct. Thereafter, the defendant consented to an interview

2 C.S. also testified that while she was alone with the defendant in the living room of the home, the defendant touched her breasts. For this incident, the defendant was charged with indecent assault and battery on a child under fourteen, in violation of G. L. c. 265 § 13B, but the jury found him not guilty. See note 1, supra.

3 which occurred at the Amherst police department. The defendant

denied any wrongdoing but acknowledged that he would play

outside with J.S. and C.S., and "grab" or "spin" them.

Discussion. 1. Uncharged prior bad acts. The defendant

contends that the judge abused his discretion by allowing the

Commonwealth to solicit testimony from J.S. that the defendant

sexually assaulted her on several other occasions. We are not

persuaded that the evidence at issue unduly prejudiced the

defendant and further conclude that the testimony did not, as

the defendant claims, amount to improper character evidence.

Prior to trial, the prosecutor filed a motion in limine

seeking to introduce testimony that the defendant sexually

assaulted J.S. on fifteen to twenty additional occasions. The

defendant opposed the motion, and, after a hearing, the judge

initially reserved ruling pending the start of trial, at which

time, he allowed the Commonwealth's motion to admit J.S.'s

testimony. He reasoned that since the uncharged acts were not

too remote in time and were between the same parties, the

evidence was relevant to show the defendant's intent and the

relationship between the parties. The defense requested, and

the judge gave, instructions limiting the jury's consideration

of this evidence both at the time J.S. testified about the prior

acts of sexual abuse and in the judge's final instructions to

the jury.

4 "It is well settled that the prosecution may not introduce

evidence that a defendant previously has misbehaved . . . for

the purposes of showing his bad character or propensity to

commit the crime charged" (citation omitted). Commonwealth v.

Morgan, 460 Mass. 277, 289 (2011). See Mass. G. Evid. § 404(b)

(2021). However, the prosecution may introduce that same

evidence for other valid reasons, including to show intent or

the relationship between the parties, so long as its probative

value is not outweighed by the danger of unfair prejudice. See

Commonwealth v. Hanlon, 44 Mass. App. Ct. 810, 817 (1998).

The defendant argues that J.S.'s testimony was marginally

probative as it did not have "specifics attached to it." This

argument is not availing. Trial judges are encouraged to limit

prior bad act testimony to establishing in "summary fashion" any

uncharged evidence of abuse. Commonwealth v. Dwyer, 448 Mass.

122, 130 (2006). In addition, "[t]he case law is particularly

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Commonwealth v. Jorge A. Castillo., Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-jorge-a-castillo-massappct-2025.