Commonwealth v. Lawrence Lamphier.

CourtMassachusetts Appeals Court
DecidedFebruary 8, 2023
Docket21-P-0025
StatusUnpublished

This text of Commonwealth v. Lawrence Lamphier. (Commonwealth v. Lawrence Lamphier.) 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. Lawrence Lamphier., (Mass. Ct. App. 2023).

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

21-P-25

COMMONWEALTH

vs.

LAWRENCE LAMPHIER.

MEMORANDUM AND ORDER PURSUANT TO RULE 23.0

A Superior Court jury convicted the defendant of sexually

assaulting two of his granddaughters when they were between the

ages of four and nine.1 On appeal, the defendant claims that

several trial errors require reversal, alone or cumulatively.

We affirm.

Discussion. 1. Multiple complaints. The defendant faults

the judge for permitting his daughter, the first complaint

witness and the mother of the victims (daughter), and a police

officer to testify about additional reports of the abuse after

the first complaint. Specifically, the daughter testified that

1 The defendant was convicted of six counts of aggravated rape, two counts of rape of a child by force, and four counts of indecent assault and battery on a child under fourteen. He was acquitted of an additional indecent assault and battery charge and of posing a child in the nude. she took the victims to a "forensic interview" and instructed

them that "they needed to be very honest, and they needed to

tell these people what happened to them"; to a meeting at the

district attorney's office; and to a "forensic exam[ination]."

In addition, Officer Jared Ulak testified that there was a one-

week delay between the initial report of the crimes and the

execution of a warrant to search the defendant's home because

"there was a SAIN interview[2] that needed to be performed." The

defendant argues that the daughter's and Ulak's testimony was

inadmissible because it "serve[d] no purpose other than to

repeat the fact of a complaint and thereby corroborate the

complainant's accusations," and that the judge failed to conduct

the "careful balancing" required to determine whether the

testimony was "relevant and admissible for reasons that are

independent of the first complaint doctrine" and not unfairly

prejudicial. Commonwealth v. Arana, 453 Mass. 214, 229 (2009).

Because the defendant did not raise this claim at trial, our

review is limited to determine whether there was any error and,

if so, whether it created a substantial risk of a miscarriage of

2 Ulak's testimony was the first reference at trial to a "SAIN interview," a term that was then repeated but never explained to the jury. The interview was first referenced in defense counsel's questioning of the older victim on cross-examination, where it was described as a recorded interview, about four years prior to trial, with a woman named Jessica. See Commonwealth v. Monteiro, 75 Mass. App. Ct. 489, 492 n.2 (2009) (explaining purpose of Sexual Abuse Intervention Network).

2 justice. See Commonwealth v. McCoy, 456 Mass. 838, 845-846

(2010).3

The prosecutor had a legitimate reason to question the

daughter briefly about the interviews the victims attended. The

defendant's theory of the case was that the daughter manipulated

the victims into accusing him of abuse because she was angry

with his decision to stop providing financial support. To

suggest that the victims had practiced and fabricated their

trial testimony, the defendant cross-examined them at length

about prior statements they had made (and, in the case of the

older victim, pictures she had drawn) during the initial

forensic interview and in meetings with "the two lawyers."4

3 The defendant did not object to the daughter's testimony that she took the victims to a forensic interview. When the prosecutor began to ask the daughter about something that occurred on June 16, 2014, defense counsel interrupted with an objection. The judge asked to "just hear the question," the prosecutor finished asking whether the victims "had a forensic interview at the Children's Advocacy Center in Fall River," and the daughter answered, "Yes." Defense counsel did not renew the objection. Nor did the defendant object to the daughter's testimony that she took the victims to interviews at the district attorney's office and to a forensic examination. The defendant did object when Ulak was asked the reason for the delay in executing the search warrant but did not state a basis for the objection. See Commonwealth v. Bonds, 445 Mass. 821, 828 (2006) (issue not preserved where objection at trial is on different grounds from those asserted on appeal). In any event, whether the defendant preserved his objection to Ulak's testimony is immaterial, as we conclude that the testimony did not violate the first complaint rule. 4 Defense counsel had also previously referred to the forensic

examination, which was favorable to the defense, in his opening statement, telling the jurors they would "hear that physical

3 Thus, before the daughter testified, the jury already knew that

the victims had reported and described the defendant's conduct

at these interviews -- which also explains why defense counsel

did not object when the prosecutor asked the daughter about them

and why the judge did not engage in any "balancing."

The brief references to the subsequent interviews did not

violate the first complaint doctrine. "[T]he admission of

multiple reports of a victim's allegations of [sexual assault]

is permissible where the evidence serves an independent purpose

and is necessary to present a fair and accurate picture of the

Commonwealth's case." Commonwealth v. Saunders, 75 Mass. App.

Ct. 505, 510 (2009), citing Commonwealth v. Monteiro, 75 Mass.

App. Ct. 489, 495 (2009). Here, the testimony was necessary and

appropriate to establish the timeline and circumstances of the

victims' various statements that had been previously introduced

as impeachment evidence during their cross-examinations. See

Commonwealth v. Torres, 86 Mass. App. Ct. 272, 277-278 (2014).

"The evidence was received for the independent purpose of

rebutting the inferences raised by the defendant's inquiries --

inquiries designed to show recent fabrication on the part of the

victim -- and was necessary for a fair understanding of the

examinations were done of the children and nothing physically was found to support [their] allegations." The victims' medical records would later be admitted in evidence without objection.

4 Commonwealth's case." Saunders, supra.

2. Testimony linking the forensic interviews with the

search warrant. The defendant argues that Ulak's testimony

about waiting to obtain the search warrant until the victims'

forensic interviews had been conducted was improper for the

additional reason that it was introduced to suggest that the

police believed the victims. See Commonwealth v. Stuckich, 450

Mass.

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Related

Commonwealth v. Flebotte
630 N.E.2d 265 (Massachusetts Supreme Judicial Court, 1994)
Commonwealth v. McCoy
926 N.E.2d 1143 (Massachusetts Supreme Judicial Court, 2010)
Commonwealth v. Torres
86 Mass. App. Ct. 272 (Massachusetts Appeals Court, 2014)
Commonwealth v. Caruso
67 N.E.3d 1203 (Massachusetts Supreme Judicial Court, 2017)
Commonwealth v. Richardson
667 N.E.2d 257 (Massachusetts Supreme Judicial Court, 1996)
Commonwealth v. Wilson
693 N.E.2d 158 (Massachusetts Supreme Judicial Court, 1998)
Commonwealth v. Beaudry
839 N.E.2d 298 (Massachusetts Supreme Judicial Court, 2005)
Commonwealth v. Bonds
840 N.E.2d 939 (Massachusetts Supreme Judicial Court, 2006)
Commonwealth v. Stuckich
879 N.E.2d 105 (Massachusetts Supreme Judicial Court, 2008)
Commonwealth v. Arana
901 N.E.2d 99 (Massachusetts Supreme Judicial Court, 2009)
Chace v. Curran
881 N.E.2d 792 (Massachusetts Appeals Court, 2008)
Commonwealth v. Monteiro
914 N.E.2d 981 (Massachusetts Appeals Court, 2009)
Commonwealth v. Saunders
915 N.E.2d 229 (Massachusetts Appeals Court, 2009)

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Commonwealth v. Lawrence Lamphier., Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-lawrence-lamphier-massappct-2023.