Commonwealth v. Joseph R. Lima.

CourtMassachusetts Appeals Court
DecidedJune 24, 2024
Docket23-P-0651
StatusUnpublished

This text of Commonwealth v. Joseph R. Lima. (Commonwealth v. Joseph R. Lima.) 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. Joseph R. Lima., (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-651

COMMONWEALTH

vs.

JOSEPH R. LIMA.

MEMORANDUM AND ORDER PURSUANT TO RULE 23.0

After a jury-waived trial, a District Court judge convicted

the defendant, Joseph R. Lima, of malicious killing of a

domestic animal, a cat, in violation of G. L. c. 266, § 112.

The defendant appeals, arguing in part that the prosecutor's

questions to a police officer witness -- which brought out that

the defendant refused to speak to the police when the police

came to question him (and after the defendant had received

Miranda warnings) -- violated the protections enunciated in

Doyle v. Ohio, 426 U.S. 610, 611, 616-619 (1976), and

constituted error that was not harmless beyond a reasonable

doubt. We agree, and accordingly vacate the defendant's

conviction.

Discussion. 1. Reference to the defendant's decision to

remain silent. The defendant first argues that his right to remain silent was violated when the prosecutor elicited

testimony from a police officer that the defendant indicated

that he did not want to speak to the police. During the direct

examination of the police officer, the prosecutor brought out

that the officer had received a complaint from the defendant's

former girlfriend, a co-owner of the cat, to the effect that the

defendant killed the cat. The officer testified that she then

went to the defendant's home, after which the following exchange

and objections occurred:

THE PROSECUTOR: "And, when you went to speak with [the defendant], did he answer any questions? Did he speak with you?"

DEFENSE COUNSEL: "Objection, Judge."

THE JUDGE: "Overruled. . . . You can answer."

THE WITNESS: "I -- So, he did not necessarily speak with me. I mean, he said words, but he did not answer any questions that I asked, if that's what you're asking."

THE PROSECUTOR: "Did he indicate that he wanted to speak with you?"

THE WITNESS: "No -- Oh, sorry."

THE JUDGE: "Overruled, given the answer."

THE PROSECUTOR: "And, would you just repeat that for the record?"

THE WITNESS: "No. . . . He did not wish to speak to us."

2 During cross-examination of the officer, defense counsel

brought out that before she started questioning the defendant,

the officer had provided the Miranda warnings:

DEFENSE COUNSEL: "And, then, as far as going to speak to [the defendant], you went and you knocked on his apartment door, right?"

THE WITNESS: "Yes."

DEFENSE COUNSEL: "And, [you] read him his Miranda warnings, correct?"

DEFENSE COUNSEL: "And, he exercised his rights under the Miranda warnings, correct?"

THE WITNESS: "Correct."

"There is no question that, under the fundamental

principles of jurisprudence, evidence of a criminal defendant's

postarrest, post-Miranda silence cannot be used for the

substantive purpose of permitting an inference of guilt."

Commonwealth v. Mahdi, 388 Mass. 679, 694 (1983). Further,

"[t]estimony regarding a defendant's statements indicating his

or her intention to remain silent are 'equally unacceptable.'"

Commonwealth v. Beneche, 458 Mass. 61, 73 (2010), quoting Mahdi,

supra at 694-695. Such an admission of a defendant's

postinvocation statement constitutes a violation of the

defendant's constitutional right to remain silent. See, e.g.,

Doyle, 426 U.S. at 617-618; Beneche, supra at 73, citing

Commonwealth v. Peixoto, 430 Mass. 654, 658-659 (2000). Here,

3 the officer's testimony that the defendant did not want to speak

to police after receiving Miranda warnings, introduced by the

prosecutor, violated these principles. 1

The Commonwealth argues, however, that if it was error to

admit the testimony, such error was harmless beyond a reasonable

doubt. See Commonwealth v. Delossantos, 492 Mass. 242, 249-253

(2023); Commonwealth v. Tiscione, 482 Mass. 485, 493 (2019). We

disagree. See Tiscione, supra at 493 (burden to show error was

harmless beyond reasonable doubt was on Commonwealth, as

"beneficiary of a constitutional error" [citation omitted]). In

considering whether a Doyle error is harmless beyond a

reasonable doubt, we consider: "(1) the relationship between

the evidence and the premise of the defense; (2) who introduced

the issue at trial; (3) the weight or quantum of evidence of

guilt; (4) the frequency of the reference; and (5) the

availability or effect of curative instructions." Mahdi, 388

Mass. at 696-697. The Supreme Judicial Court in Mahdi, id. at

698, stated that "[t]he nature of a Doyle error is so egregious

that reversal is the norm, not the exception."

1 The Commonwealth contends that it is unclear whether the officer's answers addressed prearrest or postarrest statements of the defendant. However, as revealed by defense counsel's questioning, supra, the defendant indicated that he did not wish to speak to the police after receiving his Miranda warnings.

4 Here, we cannot say that the admission was harmless error.

The first three of the Mahdi factors indicate that the error was

not harmless, particularly the relationship between the evidence

and the defense, and the strength (or lack thereof) of the

Commonwealth's case. The remaining Mahdi factors do not point

us to a different result.

As to the first and second Mahdi factors, the central

premise of the defense was that the defendant's former

girlfriend, who reported the incident, fabricated her allegation

that the defendant killed the cat. The testimony elicited by

the Commonwealth -- that the defendant refused to speak to the

police -- tended to undermine that defense, by suggesting to the

factfinder that if the defendant was being falsely accused, he

likely would have wanted to speak with the police.

Further, the strength of the evidence against the defendant

(factor 3) was not overwhelming. The Commonwealth's case hinged

almost exclusively on the testimony of the girlfriend, who

testified that the defendant admitted to her that he killed the

cat, and that she saw specks of blood on the bathroom floor at

the time of the defendant's admission. 2 Although there was some

corroboration of the girlfriend's testimony, in that the cat was

2 The girlfriend testified that the defendant stated that when he killed the cat, the cat started bleeding from its mouth.

5 not seen again, no witnesses offered testimony describing the

incident, and no physical or documentary evidence, including

photographs, were introduced by the Commonwealth. The

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Related

Doyle v. Ohio
426 U.S. 610 (Supreme Court, 1976)
Commonwealth v. Mahdi
448 N.E.2d 357 (Massachusetts Supreme Judicial Court, 1983)
Commonwealth v. Latimore
393 N.E.2d 370 (Massachusetts Supreme Judicial Court, 1979)
Commonwealth v. Forde
466 N.E.2d 510 (Massachusetts Supreme Judicial Court, 1984)
Commonwealth v. Beneche
933 N.E.2d 951 (Massachusetts Supreme Judicial Court, 2010)
Commonwealth v. Vasquez
923 N.E.2d 524 (Massachusetts Supreme Judicial Court, 2010)
Commonwealth v. Rarick
87 Mass. App. Ct. 349 (Massachusetts Appeals Court, 2015)
Commonwealth v. Tiscione
124 N.E.3d 690 (Massachusetts Supreme Judicial Court, 2019)
Commonwealth v. Peixoto
722 N.E.2d 470 (Massachusetts Supreme Judicial Court, 2000)
Commonwealth v. Kerns
871 N.E.2d 433 (Massachusetts Supreme Judicial Court, 2007)
Commonwealth v. Murungu
879 N.E.2d 99 (Massachusetts Supreme Judicial Court, 2008)
Commonwealth v. Sepheus
9 N.E.3d 800 (Massachusetts Supreme Judicial Court, 2014)
Chace v. Curran
881 N.E.2d 792 (Massachusetts Appeals Court, 2008)
Commonwealth v. Kobrin
893 N.E.2d 384 (Massachusetts Appeals Court, 2008)
Commonwealth v. Rodriguez
918 N.E.2d 865 (Massachusetts Appeals Court, 2009)

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Commonwealth v. Joseph R. Lima., Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-joseph-r-lima-massappct-2024.