Commonwealth v. Miguel Angel Rivera.

CourtMassachusetts Appeals Court
DecidedJuly 15, 2026
Docket24-P-0993
StatusUnpublished

This text of Commonwealth v. Miguel Angel Rivera. (Commonwealth v. Miguel Angel Rivera.) 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. Miguel Angel Rivera., (Mass. Ct. App. 2026).

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-993

COMMONWEALTH

vs.

MIGUEL ANGEL RIVERA.1

MEMORANDUM AND ORDER PURSUANT TO RULE 23.0

After a jury trial, the defendant was convicted of thirty-

three offenses related to his physical and sexual abuse of three

minor children. After a jury-waived trial, the defendant was

convicted of being a habitual offender. On appeal, the

defendant raises nine claims. We vacate the judgment of

conviction on count eleven of the indictment, charging attempted

indecent assault and battery on a person over the age of

fourteen, and set aside the verdict on that count. All other

judgments are affirmed.

1. Expert testimony. The defendant claims that Dr.

Stephanie Block's unobjected-to testimony regarding delayed

1 Also known as Jose Rolon or Miguel Rolon. disclosure by child sexual abuse victims requires reversal of

his convictions of rape and indecent assault and battery. In

particular, he claims that Dr. Block's testimony was not

relevant, did not serve an explanatory purpose, distorted the

fact-finding process, and improperly vouched for the child

victims. We disagree.

"A trial judge has broad discretion with respect to the

admission of expert testimony." Commonwealth v. Dockham, 405

Mass. 618, 628 (1989). "Expert testimony is required when the

testimony concerns matters beyond the common knowledge of the

jurors and will aid jurors in reaching a decision."

Commonwealth v. Berendson, 73 Mass. App. Ct. 395, 399-400

(2008), citing Commonwealth v. Frangipane, 433 Mass. 527, 533

(2001). See Commonwealth v. Hinds, 487 Mass. 212, 220-222

(2021) (expert testimony admissible where relevant and

scientifically reliable). We review a judge's decision to admit

expert testimony for an abuse of discretion. Commonwealth v.

Chism, 495 Mass. 358, 375 (2025).

Here, the defendant's abuse of the child victims began in

2016, and continued through 2020, when it was disclosed. The

defense at trial was that the child victims had fabricated the

allegations because they hated the defendant, for breaking their

cell phones and yelling at them, and wanted him out of their

2 lives. In this light, the expert testimony on delayed

disclosure was of assistance in assessing a victim witness's

testimony and relevant because jurors may equate that delay with

dishonesty.2 See Commonwealth v. Hudson, 417 Mass. 536, 540-541

(1994); Dockham, 405 Mass. at 629. Also, the jury were aware

that Dr. Block never examined or saw the child victims, which

mitigates the risk that the jury believed Dr. Block was vouching

for the victims' credibility. See Commonwealth v. Federico, 425

Mass. 844, 849 (1997). See also Commonwealth v. Quinn, 469

Mass. 641, 647-648 (2014) (risk of improper vouching "especially

acute" where expert treated victim). Finally, the judge further

minimized any potential risk of misuse by giving limiting

instructions immediately after Dr. Block's testimony, and again

in the final charge. The instructions emphasized that

credibility determinations and fact finding remained the

exclusive province of the jury. See Commonwealth v. Richardson,

423 Mass. 180, 184-185 (1996).

2 Dr. Block, who had a Ph.D. in psychology, had no familiarity with the child victims or the defendant's case, but in general, noted that children may delay the disclosure of sexual abuse because of shame, embarrassment, stigma, fear, threats, or because they were afraid of the consequences. She also noted that a victim's relationship with the abuser could result in a delayed disclosure, and that the closer the relationship, the more difficult it may be for the child to disclose.

3 2. Medical records of E.C. The defendant claims that the

convictions of rape and indecent assault and battery of E.C.,

one of the child victims, must be reversed because E.C.'s

medical records, which included her Sexual Assault Nurse

Examiner (SANE) interview, were not properly redacted and

repeatedly said that E.C. was the victim of sexual assault.

Accordingly, the defendant claims the medical records, which

were admitted in evidence without objection, created a

substantial risk of a miscarriage of justice. We disagree.

Here, the parties agreed to admit in evidence E.C.'s

medical records pursuant to G. L. c. 233, § 79, subject to

specific redactions. The defendant's trial counsel expressly

noted his satisfaction with the redactions. In this posture, we

review for error, and if one occurred, whether it created a

substantial risk of a miscarriage of justice. See Commonwealth

v. Dargon, 457 Mass. 387, 397 (2010). There was neither error,

nor an abuse of discretion. See Commonwealth v. Aviles, 461

Mass. 60, 72 (2011).

In general, hospital records are admissible in evidence

pursuant to G. L. c. 233, § 79, to the extent they relate to a

patient's treatment or medical history, but not to liability.

We are to construe the statute "liberally" and permit the

admission of medical records that directly and primarily relate

4 to diagnosis or treatment, even if those records incidentally

touch on issues of liability. Dargon, 457 Mass. at 394;

Commonwealth v. Dube, 413 Mass. 570, 573 (1992).

The defendant finds fault in E.C.'s medical records because

they "repeatedly" refer to her as a "victim of sexual assault."

The first challenged entries relayed E.C.'s descriptions of the

causes of her injuries.3 However, even if these entries did not

relate to medical diagnosis or treatment, and fell outside the

purview of G. L. c. 233, § 79, there was no substantial risk of

a miscarriage of justice from their admission. See Dargon, 457

Mass. at 397. The redacted records did not identify the

defendant as the offender, nor did they express any opinion

about his guilt. In this light, the records did not carry the

imprimatur of the hospital's belief in the defendant's guilt.

See Commonwealth v. DiMonte, 427 Mass. 233, 242 (1998).

The defendant also challenges an entry which stated, "[h]e

threatened to smash her phone and tell her mother." The

Commonwealth properly concedes that this entry does not relate

to E.C.'s treatment or medical history. See G. L. c. 233, § 79.

However, because the defendant relied on this evidence to

3 The entries included, "Pt states he does it a lot. Pt reports on Thursday early morning about 0500 he entered her room and said we had to do it. Pt clarifies he put his penis in her vagina" (quotations omitted).

5 support his defense that the child victims hated him and wanted

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