Commonwealth v. Wenbo Liu.

CourtMassachusetts Appeals Court
DecidedDecember 16, 2024
Docket24-P-0199
StatusUnpublished

This text of Commonwealth v. Wenbo Liu. (Commonwealth v. Wenbo Liu.) 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. Wenbo Liu., (Mass. Ct. App. 2024).

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-199

COMMONWEALTH

vs.

WENBO LIU.

MEMORANDUM AND ORDER PURSUANT TO RULE 23.0

After a District Court trial, a jury convicted the

defendant of three counts of indecent assault and battery,

rejecting his alibi defense. Thereafter, represented by new

counsel, the defendant moved for a new trial, asserting as

relevant here that trial counsel was ineffective in failing to

introduce expert evidence to counter a weakness in the alibi. A

judge other than the trial judge denied the motion, and the

defendant appealed. We conclude that, regardless of whether

trial counsel's performance was deficient, it did not cause the defendant sufficient prejudice to warrant a new trial. We

therefore affirm the order denying the motion. 1

Background. 1. Trial. The defendant was charged with

indecent assault and battery of a twenty year old woman who

rented a room in his home. The alleged unconsented touchings of

the victim's buttocks, breast, and vagina occurred during the

night of July 25-26, 2017; the victim estimated that they

occurred at 12:40 A.M. Because there was no physical evidence

of the offenses, the trial was largely a credibility contest.

The defendant offered an alibi defense, testifying that he was

on a lengthy FaceTime video call with his fiancé in California,

discussing their wedding plans, from about 11:50 P.M. until 2:20

A.M. His fiancé testified to the same effect. 2

Asked whether he could document the occurrence of the

FaceTime call, the defendant testified that he could not,

because after "30 day[s] or three months you won't be able to

find the history of your FaceTime records." Thus, he said,

because he had not learned of the charges against him until

November 2017, which was four months after the alleged assaults,

he was unable to retrieve a record of the call. His fiancé

The appeal was consolidated with the defendant's direct 1

appeal from his convictions, but the defendant makes no separate argument concerning the direct appeal, and therefore we affirm the judgments of conviction.

By the time of trial, the defendant and his fiancé had 2

married. For clarity we refer to her as his fiancé throughout.

2 likewise testified that she had looked for a record of their

FaceTime call that November but could not find any. On her

laptop computer, an Apple MacBook she had used for the call, she

found FaceTime records only for the preceding three months. 3

On cross-examination, the defendant testified that his

MacBook computer from which he had made the FaceTime call

retained a call log "for the past one month or something like

that," and that he had tried to retrieve the log but did not

succeed. He understood "from the Apple page" that the log

remained for only one month, and he maintained that the call log

disappeared "automatically" after thirty days, or at least by

the time he learned of the charges. This deletion was

accomplished, in his words, "not [by the] computer, it's the

system, the Apple system." He denied ever having intentionally

deleted any call logs.

In the Commonwealth's closing argument, the prosecutor

stated that there was no record of the FaceTime call -- only the

defendant's and his fiancé's testimony that it occurred -- and

suggested that the call never happened. The Commonwealth urged

3 We acknowledge the defense evidence, supported by records, that the defendant and his fiancé communicated through e-mail at 12:20 A.M., and through the WeChat messaging application between 11:31 and 11:35 P.M. and again between 12:45 and 12:50 A.M. The Commonwealth argued that this evidence nevertheless left "critical gaps" during which time the defendant could have committed the offenses. The occurrence of the FaceTime call was therefore critical to the alibi defense.

3 the jury not to believe the alibi defense and instead to believe

the victim. The jury returned verdicts of guilty on all three

charges.

2. Motion for new trial. In 2023, the defendant moved for

a new trial, alleging that trial counsel was ineffective in

failing to introduce expert evidence explaining why no records

of the July 2017 FaceTime call were available from Apple when

the defendant and his fiancé looked in November. The defendant

argued that such evidence would have shown "his failure to

present records was not evidence of fabrication but it was

simply unavoidable based on the nature of how FaceTime works."

In support of the motion, the defendant offered an affidavit

from a digital forensic analyst asserting that, in November

2017, Apple's policy with respect to law enforcement requests to

Apple for users' FaceTime records was in relevant part as

follows:

"Apple has FaceTime call invitation logs when a FaceTime call invitation is initiated. These logs do not indicate that any communication between users actually took place. FaceTime call invitation logs are retained up to 30 days. FaceTime call invitation logs, if available, may be obtained with an order under 18 U.S.C. § 2703(d) or court order with the equivalent legal standard or search warrant."

The affidavit further asserted that Apple maintained no records

of the duration of any such calls. The affidavit therefore

stated that FaceTime call invitation logs pertaining to calls

4 made in July 2017 would not have been available through Apple in

November 2017, nor would any records of the duration of such

calls have been available from Apple since no such records were

maintained. Finally, "in an effort to confirm these findings,"

the expert, using the defendant's credentials, logged into

Apple's server to search for backup files from the defendant's

device(s) that would reflect FaceTime calls and found that no

such files were available from the defendant's account.

A motion judge held an evidentiary hearing, at which the

expert testified consistently with his affidavit and stated that

he would have so testified if called as a witness at trial. 4 On

cross-examination, the expert agreed that his trial testimony

would have been limited to what records would have been

available in November 2017 from Apple. He agreed that he could

not have testified about whether there would have been records

of the July 2017 FaceTime call on the defendant's and his

fiancé's devices themselves, unless he had been "consulted back

then, as to the analysis of those devices," which he had not

been.

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