Commonwealth v. Sammy Lozada

CourtMassachusetts Supreme Judicial Court
DecidedJuly 17, 2025
DocketSJC-12985
StatusPublished

This text of Commonwealth v. Sammy Lozada (Commonwealth v. Sammy Lozada) is published on Counsel Stack Legal Research, covering Massachusetts Supreme Judicial Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Commonwealth v. Sammy Lozada, (Mass. 2025).

Opinion

SUPREME JUDICIAL COURT

COMMONWEALTH vs. SAMMY LOZADA

Docket: SJC-12985
Dates: May 5, 2025 - July 17, 2025
Present: Budd, C.J., Gaziano, Kafker, Wendlandt, Georges, Dewar, & Wolohojian, JJ.
County: Hampden
Keywords: Homicide. Practice, Criminal, Witness, Interpreter, New trial, Capital case. Interpreter. Evidence, Identification, Cross-examination. Witness, Cross-examination. Identification. Statute, Construction.

      Indictments found and returned in the Superior Court Department on July 5, 2017.

      A motion for a new trial, filed on December 7, 2021, was heard by Karen L. Goodwin, J.

      Travis H. Lynch, Assistant District Attorney, for the Commonwealth.

      Michael J. Fellows for the defendant.

      WENDLANDT, J.  The defendant, Sammy Lozada, was convicted of murder in the first degree for the stabbing death of Carlos Ramos (victim).  The stabbing occurred in the Holyoke apartment of Maria Samot, who was the prosecution's key identification witness at trial.  Samot is deaf, illiterate, and severely language deprived; she lacks the ability to communicate in any recognized language, including American Sign Language (ASL).  Instead, Samot communicates using a limited set of idiosyncratic gestures grounded in her Hispanic cultural background.  At trial, her testimony was presented by a team of two certified deaf interpreters and two ASL interpreters. 

      No determination regarding the appropriateness of these interpreters in view of Samot's severe communication challenges was made as required by G. L. c. 221, § 92A (§ 92A or statute). Specifically, the statute mandates that "no testimony shall be admitted as evidence until" the trial judge determines that an interpreter can communicate accurately with, and translate to and from, a deaf witness.  G. L. c. 221, § 92A, third par.  This lapse proved especially problematic during Samot's testimony on cross-examination when trial counsel asked her questions that elicited dozens of nonresponsive answers repeatedly stating that the defendant stabbed the victim. 

      Following his conviction, the defendant filed a motion for a new trial, contending that "justice had not been done" because of noncompliance with the statute.  See Mass. R. Crim. P. 30 (b), as appearing in 435 Mass. 1501 (2001).  The motion judge, who was also the trial judge, held an evidentiary hearing at which experts specializing in communications with severely language deprived persons testified as to the extent of Samot's communications challenges and opined that the team of interpreters provided to Samot at trial often were unable to communicate with Samot or translate to and from her accurately.  The judge, who herself had observed the communication missteps during the trial, credited the experts' testimony and found, inter alia, that the error in failing to make the determination required under § 92A, third par., raised a substantial risk of a miscarriage of justice.  Accordingly, she allowed the defendant's motion. 

      The Commonwealth appealed.  Concluding that the judge did not abuse her discretion in allowing the motion, we affirm. 

      1.  Background.  a.  Facts.  We summarize the facts as the jury could have found them, reserving certain details for later discussion.  See Commonwealth v. Wiggins, 477 Mass. 732, 734 (2017).

      In the early morning of April 28, 2017, Jose Espada was walking on Maple Street in Holyoke when he encountered the defendant and his associate, Madeline Garcia.  Espada, who was homeless, was on his way to a friend's vehicle to sleep; he was carrying a brown-handled knife with a one-inch wide blade and his tablet computer device.  The defendant took the tablet from him, saying, "Now this is mine."  After a failed attempt to recover his property, Espada went to a nearby corner store.  A few moments later, however, the defendant and Garcia found Espada and asked him to unlock his tablet so that they could "hock" it for twenty dollars.  Espada acquiesced, in part because the defendant offered to let him sleep at the defendant's home.

      The defendant, Garcia, and Espada walked to an apartment building on Maple Street.  The defendant and Garcia entered an apartment while Espada remained outside the apartment door.  Approximately five minutes later, the defendant and Garcia emerged from the apartment without the tablet.  The trio then proceeded to the defendant's home on High Street.  Espada had planned to sleep on the defendant's couch but decided against it, telling the defendant that he was going to sleep in his friend's vehicle.  In response, the defendant announced his intent to get the tablet back right then.

      The cohort returned to the apartment building on Maple Street and ascended the stairs to the apartment they had visited previously.  After knocking on the door and receiving no answer, the defendant kicked the door open and asked Garcia, "Baby, are you ready?"  The defendant and Garcia then entered the apartment, while Espada remained outside on the porch.  From outside, Espada heard someone asking, "Sammy, what's going on?"  Then he heard screaming.  Espada peered inside; he saw the defendant holding a black-handled knife and the victim leaning over the sink with blood on the front of his shirt.  He also saw Samot in the room.  The defendant demanded to know where the tablet was.  In response, the victim asked "Sammy" not to stab him again because, in his words, he was "already dying." 

      Espada saw the defendant leave the apartment, tablet in hand.  By then, the victim had made his way to the porch; he grabbed onto Espada before falling on the ground face first.  Believing that the victim was dead, Espada fled down Maple Street; in his flight path, he tossed the brown-handled knife he had been carrying into bushes, where it was subsequently recovered by police.

      Responding Holyoke police officers found the victim prone and bleeding.  He was taken to a hospital, where he was pronounced dead at 3:13 A.M. that same early morning.  On entering the Maple Street apartment, police found Samot in a frantic state.  She was taken to the police station, where officers interviewed her with the assistance of two interpreters -- both of whom would subsequently provide interpretation services for Samot during her testimony at the defendant's trial.  During the police interview, Samot identified photographs of both the defendant and Garcia from two different photographic arrays.[1]

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Commonwealth v. Sammy Lozada, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-sammy-lozada-mass-2025.