Commonwealth v. Keith D. Correia.

CourtMassachusetts Appeals Court
DecidedApril 9, 2024
Docket22-P-1020
StatusUnpublished

This text of Commonwealth v. Keith D. Correia. (Commonwealth v. Keith D. Correia.) 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. Keith D. Correia., (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

22-P-1020

COMMONWEALTH

vs.

KEITH D. CORREIA.

MEMORANDUM AND ORDER PURSUANT TO RULE 23.0

Following a jury trial in the District Court, the defendant

was convicted of larceny of a motor vehicle, negligent operation

of a motor vehicle, and leaving the scene of property damage.

On appeal, the defendant maintains that (1) identification

testimony from eyewitnesses violated Commonwealth v. Crayton,

470 Mass. 228, 237, 242-243 (2014); (2) his trial counsel was

ineffective; and (3) the evidence against him was insufficient.

We affirm.

Background. The jury could have found that, on the evening

of February 19, 2019, a couple leaving a restaurant saw the

defendant checking the door handles of cars parked on the

street, apparently to see if they were unlocked. After getting

into their own car, the couple drove to a nearby parking lot,

where they saw what appeared to be the same person "rummaging through a car." The wife called the police to report what they

saw, and the couple then saw the defendant move to a different

car, a gray Nissan Pathfinder. The defendant got into the

Pathfinder and drove it out of the lot. The couple started to

follow behind in their own car. They saw the Pathfinder almost

hit another vehicle, accelerate through an intersection, and hit

two other vehicles along the street, which caused one of the

Pathfinder's tires to pop and the rim of the wheel to spark.

There was a trail of "either oil or coolant" which the couple

followed, eventually finding the Pathfinder "smashed" into

another vehicle, with the same man they witnessed on the street

and in the parking lot earlier (the defendant) walking away from

the accident. Both members of the couple testified that they

recognized the man by his jacket and hat, though the wife

testified that the two had disagreed on the color of the man's

jacket. The wife had been on the phone with the police while

the couple was following the Pathfinder. When police arrived at

the scene, the husband directed the police to the defendant, who

was then walking away from the car, and he was arrested.

The defendant filed a motion in limine to prevent in-court

identifications at trial. The judge took no action on the

motion, reserving a ruling until in-court identifications

occurred. The couple had differing initial accounts of the

defendant's appearance -- they disagreed about the color of his

2 jacket, and while the husband thought the defendant was white,

the wife thought he had dark skin.

During the husband's testimony, he was asked about his

ability to recognize the person he had seen and said that he had

recognized the defendant "as soon as he walked through the

courtroom doors this morning." The defendant objected to the

statement as impermissibly suggestive but did not move to strike

the identification or ask for a curative jury instruction. The

judge instructed the Commonwealth to lay a foundation before

prompting an in-court identification of the defendant but did

not sustain the objection or (sua sponte) strike the statement.

The husband then testified that he did not get a good look at

the person's face, and the Commonwealth did not pursue the

issue.

The wife also testified that she had not gotten a good look

at the driver's facial features and that she had recognized him

by his clothing, but she was nonetheless confident in her

ability to identify the driver. The judge overruled the

defendant's objection to the identification. The wife then

identified the defendant.

The arresting officer testified and identified the

defendant at trial as well. That officer had also taken some

items from the defendant's person after detaining him, including

a Nissan car key with a broken loop. Over the defendant's

3 objections, photos of the key and booking photos were entered

into evidence.

Discussion. 1. In-court identifications. The defendant

maintains that both the husband's and wife's in-court

identifications were Crayton errors. Under Crayton, 470 Mass.

at 237, 242-243, if there was no prior out-of-court

identification, an in-court identification is only allowed if

there is a "good reason." "Good reasons" include "where the

eyewitness was familiar with the defendant before the commission

of the crime," and "where the witness is an arresting officer

who was also an eyewitness to the commission of the crime, and

the identification merely confirms that the defendant is the

person who was arrested for the charged crime." Id. at 242.

"In both of these circumstances, the in-court [identification]

is understood by the jury as confirmation that the defendant

sitting in the court room is the person whose conduct is at

issue rather than as identification evidence." Id.

The Commonwealth bears the burden of showing good reason

for the in-court identification. See Crayton, 470 Mass. at 243.

Here, with respect to the identifications by the couple, the

Commonwealth asserted that the couple had directed the police to

the scene. There had been no out-of-court identification

procedure like a "showup" or a photo array. The couple was not

previously familiar with the defendant. See id. at 242.

4 Because there was no good reason for the judge to allow in-court

identifications from the couple, the trial judge erred by

denying the defendant's motion in limine to prevent such

identifications, and by overruling the defendant's objections to

the wife's in-court identification. However, these errors did

not prejudice the defendant. See Commonwealth v. Ortiz, 487

Mass. 602, 610-611 (2021). Given the strength of the other

evidence presented to the jury, including an arresting officer's

in-court identification of the defendant,1 the errors "did not

influence the jury, or had but very slight effect." Id. at 610,

quoting Commonwealth v. Brown, 456 Mass. 708, 725 (2010), S.C.,

466 Mass. 1007 (2013).

The husband's in-court identification stands on slightly

different footing from the wife's; it was not responsive to the

Commonwealth's questioning but was instead spontaneous. The

defendant objected, which resulted in the judge's instructing

the Commonwealth to lay the foundation for an identification.

After failing to do so, the Commonwealth did not pursue an

identification from the husband. The defendant did not move to

strike the husband's unprompted statement or request a

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Commonwealth v. Crayton
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Cite This Page — Counsel Stack

Bluebook (online)
Commonwealth v. Keith D. Correia., Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-keith-d-correia-massappct-2024.