Commonwealth v. Sonn Ke.

CourtMassachusetts Appeals Court
DecidedAugust 14, 2025
Docket24-P-0781
StatusUnpublished

This text of Commonwealth v. Sonn Ke. (Commonwealth v. Sonn Ke.) 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. Sonn Ke., (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

24-P-781

COMMONWEALTH

vs.

SONN KE.

MEMORANDUM AND ORDER PURSUANT TO RULE 23.0

Following a jury trial in the Superior Court, the defendant

was convicted of aggravated rape of a child (by more than a ten-

year age difference) and forcible rape of a child.1 On appeal,

the defendant argues that the judge erred in admitting evidence

of prior uncharged sexual assaults by the defendant against the

victim. Discerning no abuse of discretion or other error of

law, we affirm.

Background. The jury could have found the following facts

based on the evidence presented at trial. Prior to moving to

Massachusetts, the victim lived in California with her mother,

1The defendant was acquitted of three counts of indecent assault and battery on a child. siblings, and the defendant, her stepfather. The defendant

began sexually assaulting the victim when she was in the third

or fourth grade. The family moved to Massachusetts when the

victim was in the seventh or eighth grade. The defendant

continued his sexual assaults on the victim. The victim began

devising a plan to run away.

During her freshman year of high school, when she was

fifteen years old, the victim took an opportunity she had while

outside of her house to call her older stepbrother; he was in

the military and stationed abroad. She told him what the

defendant had been doing to her. Although she had hoped to run

away from home that day before her mother came back from work,

the victim's plans were dashed when she was caught. Back at

home, the victim's mother asked why she was so upset. The

victim told her mother what the defendant had been doing to her.

The victim's mother confronted the defendant, who denied it.

After the confrontation, the defendant did not sexually assault

the victim again, but he continued to live with the family.

The year the victim graduated from high school she moved

back to California. The victim's older stepbrother then

reported the defendant's crimes against the victim to the

police.

Discussion. The Commonwealth filed a motion in limine to

admit evidence of the defendant's sexual assaults against the

2 victim which took place in California. The defendant filed a

motion in limine to exclude these prior acts of sexual assault.

The judge allowed evidence of prior sexual assaults in

California to be admitted for the purpose of establishing the

nature of the defendant's relationship with the victim, a

pattern or course of conduct, state of mind, intent, method, or

a modus operandi. The judge limited this evidence to prior

conduct that is the same as the charged conduct only.2

On appeal, the defendant contends that evidence of the

California sexual assaults on the victim was so pervasive that

it tainted the evidence regarding the charged sexual assaults.

He points in particular to a jury question regarding the

California sexual assaults as supporting the view that the jury

used the prior bad act evidence in an improper and prejudicial

manner. A judge's ruling on the admission of prior bad act

evidence is reviewed for an abuse of discretion. See

Commonwealth v. Nascimento-Depina, 496 Mass. 1, 8 (2025).

Prior bad act evidence is inadmissible for the purpose of

demonstrating a defendant's bad character or propensity to

commit the charged crime. See Commonwealth v. Crayton, 470

Mass. 228, 249 (2014); Mass. G. Evid. § 404(b)(1) (2025). It is

2 The judge ruled that any evidence of the defendant's prior bad acts relating to the victim's younger stepsister was excluded.

3 admissible when it is relevant to establish the defendant's

"motive, opportunity, intent, preparation, plan, knowledge,

identity, or pattern of operation." Crayton, 470 Mass. at 249,

quoting Commonwealth v. Walker, 460 Mass. 590, 613 (2011); see

Mass. G. Evid. § 404(b)(2) (2025). It is also admissible to

establish a common course of conduct or the nature of the

relationship between the victim and the defendant. See

Commonwealth v. Barrett, 418 Mass. 788, 793-794 (1994). See

also Nascimento-Depina, 496 Mass. at 8 (where defendant charged

with sexual assault, some evidence of similar uncharged conduct

may be admissible to give jury view of entire relationship

between defendant and victim). Because prior bad act evidence

has an inherent risk of prejudice, however, it should only be

admitted if its probative value is outweighed by the risk of

unfair prejudice to the defendant. See Commonwealth v. Baker,

440 Mass. 519, 530 (2003); Mass. G. Evid. § 404(b)(2).

Here, the prior bad act evidence was probative. The

California sexual assaults involved the same child victim, took

place in the same setting (the family home), and occurred close

in time to the charged conduct. Cf. Commonwealth v. Brusgulis,

406 Mass. 501, 504-505 (1990) (evidence that defendant committed

similar crimes against different victims generally

inadmissible). It shed light on the relationship between the

defendant and the victim and provided context for the charged

4 assaults in Massachusetts, a course of conduct which began in

California. See Barrett, 418 Mass. at 793-794 (evidence of

similar misconduct as charged crime admissible to show nature of

relationship between defendant and victim). See also

Commonwealth v. Childs, 94 Mass. App. Ct. 67, 71-72 (2018)

(prior bad act evidence of uncharged conduct against same victim

probative of continuing course of conduct, and testimony of

victim would "make little sense" without context of continuous

sexual abuse).

At the same time, the risk of prejudice was slight given

the prosecutor's limited inquiry into the subject.3 Moreover,

the prosecutor referred to the evidence only briefly in closing

to portray a pattern of escalating conduct and even paused to

remind the jury of the purpose of the California sexual assault

evidence. Contrast Commonwealth v. Dwyer, 448 Mass. 122, 128

(2006) (jury were provided with detailed evidence of seven

uncharged acts of sexual abuse by defendant, and more time was

spent on both direct and cross-examination exploring those prior

bad acts than crimes charged).

3 The victim testified that the sexual abuse began with the defendant touching her butt repeatedly until it became "normalized." She went on to say that the defendant would place her hand on his penis, so that she could feel the marble-like objects he had inserted along the shaft, under the skin. She described the first time he had raped her.

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Related

Commonwealth v. Barrett
641 N.E.2d 1302 (Massachusetts Supreme Judicial Court, 1994)
Commonwealth v. Brusgulis
548 N.E.2d 1234 (Massachusetts Supreme Judicial Court, 1990)
Commonwealth v. Crayton
21 N.E.3d 157 (Massachusetts Supreme Judicial Court, 2014)
Commonwealth v. Almeida
96 N.E.3d 708 (Massachusetts Supreme Judicial Court, 2018)
Commonwealth v. Bryant
128 N.E.3d 40 (Massachusetts Supreme Judicial Court, 2019)
Commonwealth v. Stone
73 N.E.2d 896 (Massachusetts Supreme Judicial Court, 1947)
Commonwealth v. Baker
800 N.E.2d 267 (Massachusetts Supreme Judicial Court, 2003)
Commonwealth v. Butler
839 N.E.2d 307 (Massachusetts Supreme Judicial Court, 2005)
Commonwealth v. Dwyer
859 N.E.2d 400 (Massachusetts Supreme Judicial Court, 2006)
Commonwealth v. Walker
953 N.E.2d 195 (Massachusetts Supreme Judicial Court, 2011)
Chace v. Curran
881 N.E.2d 792 (Massachusetts Appeals Court, 2008)

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Commonwealth v. Sonn Ke., Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-sonn-ke-massappct-2025.