Commonwealth v. Parnel Bogard.

CourtMassachusetts Appeals Court
DecidedJanuary 29, 2025
Docket23-P-1345
StatusUnpublished

This text of Commonwealth v. Parnel Bogard. (Commonwealth v. Parnel Bogard.) 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. Parnel Bogard., (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

23-P-1345

COMMONWEALTH

vs.

PARNEL BOGARD.

MEMORANDUM AND ORDER PURSUANT TO RULE 23.0

After a jury trial, the defendant was convicted of rape.

On appeal, the defendant claims errors in: the admission of

evidence that he maintains violated the first complaint rule;

the absence of a contemporaneous first complaint jury

instruction; the admission of evidence regarding his indictment;

and the prosecutor's closing argument. Although none of these

claims were preserved at trial, the defendant claims they

resulted in a substantial risk of miscarriage of justice. We

affirm.

1. First complaint. The defendant claims that several

portions of the first complaint testimony violated the first

complaint doctrine. The first claimed violation is that the first complaint witness's testimony contained details that

exceeded the scope of the victim's testimony. In particular,

the defendant claims that the witness reported that the victim

told the defendant "no," to "stop," and to "get off," but the

victim herself did not testify to these details. At oral

argument, defense counsel essentially withdrew this claim as it

was not supported by the record. The victim actually did

testify to having said these words to the defendant. In any

event, first complaint testimony need not replicate precisely

the victim's own testimony as the rule tolerates some

inconsistency. Commonwealth v. Rivera, 83 Mass. App. Ct. 581,

586-587 (2013). See Commonwealth v. King, 445 Mass. 217, 235

(2005), cert. denied, 546 U.S. 1216 (2006).

The defendant next claims that the first complaint witness

impermissibly testified to the victim's complaints to other

people. Specifically, the witness testified that after hearing

the victim's complaint they contacted a "lawyer friend" to

discuss the victim's "options." Thereafter, they went to the

police station, and both gave statements to the police. The

defendant claims this testimony enhanced the victim's

credibility and prejudiced him. We need not determine whether

it was error to admit this testimony where its admission did not

create a substantial risk of a miscarriage of justice.

2 In light of the defense of fabrication, the first complaint

witness's explanation of the discussions that occurred in the

aftermath of the complaint, i.e., speaking to an attorney about

the available "options," without ever going so far as to testify

that they "told" the lawyer, or said "what happened," would have

had little if any impact in bolstering the victim's credibility.

Contrast Commonwealth v. Arana, 453 Mass. 214, 222-223 (2009)

(witness testified that he spoke to victim nightly "about what

happened"). Relative to reporting the matter to the police, the

first complaint witness testified to only limited details of

what was said to the police, i.e., that she told the police that

the victim said she had been raped. However, this was no more

than what defense counsel told the jury in her opening

statement.

Despite this, the defendant also claims that the first

complaint witness put details of the investigative process

before the jury. However, the defendant put the investigative

details before the jury in his opening statement and his closing

argument to maintain that, despite experienced detectives

conducting a thorough investigation, police chose not to charge

the defendant. This further illustrates how the defendant

suffered no prejudice, and no substantial risk of a miscarriage

of justice was created.

3 The defendant next claims that the first complaint witness

improperly described her response to the victim's complaint. In

particular, he claims that the testimony that the witness was

"in shock" when the victim made the complaint was irrelevant and

improperly appealed to the jury's sympathies. We disagree.

In general, a first complaint witness's emotional response

to a victim's disclosure of a sexual assault is not relevant.

See Commonwealth v. Quincy Q., 434 Mass. 859, 875 (2001).

However, if there is an independent purpose for the evidence, it

may be admitted. Here, the witness stated that "I was just in

shock, and was just listening to what she had to say, but I

don't really remember the details, it's been a long time."

Thus, in context, the witness's testimony regarding her shock

was relevant to her inability to recall the details of the

complaint, and was not an attempt to buttress the victim's

credibility. 1

2. Lack of a contemporaneous jury instruction. The

defendant also claims that the lack of a contemporaneous first

complaint limiting instruction prior to the victim's or the

first complaint witness's testimony resulted in a substantial

risk of miscarriage of justice. We disagree.

1 The defendant also claims the cumulative effect of the first complaint violations created a substantial risk of a miscarriage of justice. Having found no individual violation created such a risk, the argument is without merit.

4 "[A]lthough a contemporaneous [first] complaint instruction

is recommended, it is 'not a strict requirement.'" Commonwealth

v. Lewis, 91 Mass. App. Ct. 651, 663 (2017), quoting

Commonwealth v. Edward, 75 Mass. App. Ct. 162, 166 (2009).

Here, the victim's testimony regarding her report of the rape to

the first complaint witness was very brief, and without detail.

The first complaint witness's testimony was also brief and

focused primarily on the victim's demeanor at the time of her

complaint. Her account was devoid of any details of the

victim's complaint because she did not "remember the details,

[and it had] been a long time." When asked if the victim stated

it was consensual, the witness could not remember the "exact

words" the victim used, but it was likely the victim gave her a

description. Given the victim's demeanor, the witness

understood it was not consensual, but she did not "recall the

specifics of what [the victim] described."

The first complaint witness was the last witness to testify

at the defendant's trial. After closing arguments, the judge

gave his final instructions to the jury. Those instructions

included a limiting instruction on the proper use of first

complaint evidence, and the defendant does not claim otherwise.

Although the instruction was not contemporaneous with the first

complaint testimony, it occurred in fewer than two hours after

that witness testified.

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Commonwealth v. Parnel Bogard., Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-parnel-bogard-massappct-2025.