Commonwealth v. Sosa

CourtMassachusetts Supreme Judicial Court
DecidedNovember 30, 2023
DocketSJC 12166
StatusPublished

This text of Commonwealth v. Sosa (Commonwealth v. Sosa) 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.

Bluebook
Commonwealth v. Sosa, (Mass. 2023).

Opinion

NOTICE: All slip opinions and orders are subject to formal revision and are superseded by the advance sheets and bound volumes of the Official Reports. If you find a typographical error or other formal error, please notify the Reporter of Decisions, Supreme Judicial Court, John Adams Courthouse, 1 Pemberton Square, Suite 2500, Boston, MA, 02108-1750; (617) 557- 1030; SJCReporter@sjc.state.ma.us

SJC-12166

COMMONWEALTH vs. AMADI SOSA.

Hampden. May 5, 2023. - November 30, 2023.

Present: Budd, C.J., Gaziano, Cypher, Kafker, & Georges, JJ.

Homicide. Armed Assault with Intent to Rob. Firearms. Due Process of Law, Accomplice testimony. Constitutional Law, Confrontation of witnesses. Evidence, Videotape, Joint venturer, Intent. Joint Enterprise. Intent. Practice, Criminal, Severance, Trial of defendants together, Cross- examination by prosecutor, Confrontation of witnesses, Instructions to jury, Capital case, New trial, Assistance of counsel, Motion to suppress. Search and Seizure, Expectation of privacy.

Indictments found and returned in the Superior Court Department on February 11, 2014.

The cases were tried before Daniel A. Ford, J.; a motion for a new trial, filed on August 23, 2019, was heard by Douglas H. Wilkins, J., and a motion for reconsideration was considered by him.

John M. Thompson (Linda J. Thompson also present) for the defendant. David L. Sheppard-Brick, Assistant District Attorney, for the Commonwealth. 2

GEORGES, J. This is a companion case to Commonwealth v.

Leiva, 484 Mass. 766 (2020). There, we affirmed the convictions

of Julio Brian Leiva, who was tried together with the defendant

for the shooting death of William Serrano during an attempted

robbery. Id. at 767, 769, 770 n.2. A Hampden County jury

convicted the defendant of murder in the first degree on

theories of deliberate premeditation and felony-murder, as well

as armed assault with the intent to rob and unlawful possession

of ammunition. Before us are the defendant's consolidated

appeals from his convictions and from the denial of his motion

for a new trial.

The defendant has asserted numerous errors. He contends

that the trial judge erred by (1) denying the defendant's motion

for relief from prejudicial joinder, or otherwise failing to

sever his trial from that of his codefendant, Leiva; (2)

allowing the prosecutor to use an unauthenticated video

recording during the course of trial; (3) denying the

defendant's motion for a required finding of not guilty on the

charge of murder in the first degree; (4) failing to instruct

the jury on an essential element of the charge of unlawful

possession of ammunition; and (5) failing to instruct the jury

on involuntary manslaughter. The defendant further contends,

with respect to his motion for a new trial, that the motion

judge erred both in failing to hold an evidentiary hearing and 3

in denying the defendant's motion. Finally, the defendant

requests relief pursuant to G. L. c. 278, § 33E.

We discern no reversible error with respect to the

defendant's convictions of murder in the first degree and armed

assault with the intent to rob. Additionally, after a thorough

review of the record, we decline to exercise our authority under

G. L. c. 278, § 33E. Accordingly, we affirm the defendant's

convictions of murder in the first degree and armed assault with

the intent to rob. We also affirm the denial of the defendant's

motion for a new trial. However, because of an error in the

jury instructions, the defendant's conviction of unlawful

possession of ammunition must be vacated.

1. Background. a. Facts. We summarize the facts the

jury could have found, reserving further discussion of the facts

for our analysis infra.

On November 10, 2013, the day of the shooting, the victim

joined his girlfriend for dinner at her sister's residence in

Springfield. About twenty minutes after the couple arrived,

Leiva joined them, uninvited. Leiva and the victim's girlfriend

had previously dated, ending their relationship about six months

prior to the shooting; they remained friendly after their

relationship ended.

Leiva stayed in the kitchen for about thirty minutes,

eating and sending text messages on his cell phone before 4

abruptly leaving and returning about fifteen minutes later.

After another ten to fifteen minutes had passed, Leiva departed

again. He left through the back door of the house onto a small

porch where he passed by the victim, who was seated in a chair

with the girlfriend on his lap. Leiva, the victim, and the

girlfriend were the only people on the porch.

The girlfriend observed the defendant walk down the porch

stairs, then around to the right, where he disappeared behind

the porch. A few minutes later, Leiva reemerged from behind the

porch, followed closely by two men in dark sweatshirts with

raised hoods. The girlfriend recognized one of the men as the

defendant, a friend of Leiva, whom she had known for over six

months and with whom she frequently socialized. As the three

men approached the porch steps, the girlfriend could see that

Leiva was carrying what appeared to be a shotgun or rifle with a

sawed-off barrel.1 She had previously seen this same gun at the

defendant's residence.

Coming onto the porch, Leiva first pointed the barrel of

the gun at the girlfriend, who was attempting to block the top

of the stairway. The three men pushed past her and surrounded

the victim, with Leiva now aiming the gun at the victim's chest.

Leiva then instructed the other two men to "run his pockets," at

1 Police never recovered the gun used by Leiva. 5

which point the two men bent over to reach into the victim's

pockets. Although the girlfriend did not see what, if anything,

they retrieved, the victim was in possession of two cell phones

earlier that evening, and only one was discovered among the

victim's belongings.

When the victim, who was still seated in the chair, pleaded

to be left alone, Leiva shot the victim seven times. The

defendant and the other man stood on either side of Leiva,

looking on while facing the victim as the shots rang out.

Hearing the gunshots, the girlfriend's sister called 911.

Several minutes later, a responding officer entered the sister's

living room and found the victim, who, while screaming and

bleeding, had managed to crawl inside. The victim was

transported to the hospital, where he later died in surgery.

After leaving the area, Leiva explained to a friend that he

"went to go rob somebody" while he was with two associates but

that things went wrong.

b. Procedural history. In February 2014, a Hampden County

grand jury indicted the defendant for murder in the first

degree, G. L. c. 265, § 1; armed assault with intent to murder,

G. L. c. 265, § 18 (b); armed robbery, G. L. c. 265, § 17; armed

assault with intent to rob, G. L. c. 265, § 18 (b); and unlawful

possession of ammunition, G. L. c. 269, § 10 (h). 6

The defendant's joint trial with his codefendant, Leiva,

commenced in January 2016. Before trial, defendant's counsel

filed a motion for relief from prejudicial joinder, seeking to

sever the two cases on the grounds that the defenses would be

antagonistic.

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