ELI PARISEAU

CourtMassachusetts Appeals Court
DecidedJanuary 28, 2026
Docket24-P-0608
StatusUnpublished

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Bluebook
ELI PARISEAU, (Mass. Ct. App. 2026).

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-608

ELI PARISEAU, petitioner.

MEMORANDUM AND ORDER PURSUANT TO RULE 23.0

On July 30, 2010, a Superior Court judge adjudicated Eli

Pariseau, the petitioner, a sexually dangerous person and

committed him to the Massachusetts Treatment Center. The

petitioner filed a petition pursuant to G. L. c. 123A, § 9 for

examination and discharge to determine whether he remained

sexually dangerous on June 21, 2019. After a trial, on January

19, 2023, a jury returned a verdict that the petitioner remains

sexually dangerous. The petitioner appeals, arguing that

(1) the prosecutor's admittedly erroneous closing argument

prejudiced the petitioner, (2) the judge improperly "allowed the

Commonwealth's experts to testify to the "above average" risk of

reoffense they assigned to the petitioner through the Static- 99R, 1 (3) the judge improperly allowed testimony on uncharged

allegations of the petitioner's misconduct, and (4) the judge

improperly excluded evidence that the petitioner was

preclassified as a level three sex offender by the Sex Offender

Registry Board (SORB). We affirm. 2

Discussion. Because the petitioner did not object to the

closing argument or to the testimony of uncharged allegations of

the petitioner's misconduct, 3 those claims were not preserved,

and we therefore review to determine whether any error created a

substantial risk of a miscarriage of justice. 4 See R.B.,

1 The Static-99R is an actuarial tool that predicts an adult male sex offender's likelihood of reoffending based on a number of static factors, including, inter alia, the offender's age and number of prior sex offenses. Commonwealth v. George, 477 Mass. 331, 335 n.2 (2017).

2 After his January 2023 trial, a jury again found the petitioner to be sexually dangerous on September 12, 2025. The petitioner is scheduled for another trial, pursuant to G. L. c. 123A, § 9, on November 2, 2026. Because many of the same issues raised here are likely to arise again in the petitioner's subsequent trials pursuant to § 9, we exercise our discretion to review the petitioner's claims of error. See Thaddeus v. Secretary of the Executive Office of Health & Human Servs., 101 Mass. App. Ct. 413, 418 (2022).

3 The petitioner contends that he preserved the uncharged conduct issue by raising it in a motion in limine prior to trial. However, counsel for the petitioner conceded that the alleged conduct was admissible if it related to an offense for which the petitioner was convicted and did not object when witnesses for the Commonwealth referenced the uncharged conduct. See Mass. G. Evid. § 103(a)(1) note (2025).

4 The petitioner argues that he preserved his argument in a motion in limine in which he asked the court to preclude the

2 petitioner, 479 Mass. 712, 717-718 (2018). The petitioner

preserved his other claims, which we review for prejudicial

error. See Green, petitioner, 475 Mass. 624, 629 (2016).

1. Closing argument. During closing argument, in an

effort to convey to the jury the risk of the petitioner's

likelihood to reoffend the prosecutor asked the jury to imagine

whether they were willing to eat from a box of one hundred

cookies where they knew twelve to eighteen of the cookies were

fatally poisonous, thereby analogizing to an estimate of the

petitioner's likelihood of reoffending. 5 The argument was nearly

identical to one that a panel of this court previously concluded

was improper. 6 See DeAmicis, petitioner, 104 Mass. App. Ct. 1112

(2024). In that case the panel reasoned as follows.

"Although the Supreme Judicial Court has held that the seriousness of the harm is a factor in determining likelihood of reoffense, see [Commonwealth v. Boucher, 438

Commonwealth from arguing that it was the jury's responsibility to protect public safety. However, in allowing the motion, the judge explicitly distinguished raising concerns about public safety from raising the petitioner's risk of reoffense, noting that the latter was permissible.

5 Two expert witnesses for the Commonwealth testified that of the sex offenders who receive the same score as the petitioner from the administration of the Static-99R, 12.8 percent sexually reoffend within five years and 18.8 percent sexually reoffend within ten years.

6 The prosecutor in the present case, who was also the prosecutor in DeAmicis, petitioner, did not have the benefit of this decision when he used the argument again here and stated that he stopped making the argument when it was challenged on appeal.

3 Mass. 274, 276 (2002)], the question before the jury is whether the risk is 'likely.' See G. L. c. 123A, § 1. The prosecutor's analogy to poison cookies, however, implies that in the defendant's case, any amount of risk is too great a risk. That is a misstatement of the law, and the prosecutor's analogy was thus improper."

Id.

The Commonwealth concedes the argument was improper and we

agree. Nevertheless, the closing argument did not create a

substantial risk of a miscarriage of justice. The Commonwealth

presented strong evidence that the petitioner remained sexually

dangerous, including the fact that he sexually reoffended twice,

continues to deny any criminal conduct, and engaged in treatment

only for a limited time before stopping treatment altogether,

and engaged in consensual sex with another resident of the

treatment center -- against the treatment center's policies --

just months prior to his trial. In addition, the judge twice

instructed the jury that closing arguments are not evidence,

including one time immediately before closing arguments were

presented to the jury. See Commonwealth v. Andrade, 468 Mass.

543, 549 (2014) ("The jury are presumed to follow the judge's

instructions").

2. Static-99R risk category labels. "The Static-99R is an

actuarial tool, designed to predict the recidivism risk of

sexual offenses in adult male sex offenders who have been

convicted of at least one sexual offense." Commonwealth v.

4 George, 477 Mass. 331, 335 n.2 (2017). In George, the Supreme

Judicial Court held that the previously used risk-of-reoffense

categories that labeled an adult male sexual offender's risk of

reoffense as "low," "low-moderate," "moderate-high," and "high,"

were inadmissible because they "lack[ed] probative value in the

sexual dangerousness calculus and should not be admitted at

trial," id. at 339-340, but noted that "[t]o resolve the

shortcomings of the Static-99R risk category labels, test

developers have created new risk category labels, and "[the

court] take[s] no position on the admissibility of those

labels," id. at 340 n.8.

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Related

Green
59 N.E.3d 1127 (Massachusetts Supreme Judicial Court, 2016)
Commonwealth v. George
477 Mass. 331 (Massachusetts Supreme Judicial Court, 2017)
Josselyn v. Ames
3 Mass. 274 (Massachusetts Supreme Judicial Court, 1807)
Commonwealth v. Given
808 N.E.2d 788 (Massachusetts Supreme Judicial Court, 2004)
Moe v. Sex Offender Registry Board
467 Mass. 598 (Massachusetts Supreme Judicial Court, 2014)
Commonwealth v. Andrade
468 Mass. 543 (Massachusetts Supreme Judicial Court, 2014)
Commonwealth v. Starkus
867 N.E.2d 811 (Massachusetts Appeals Court, 2007)
Chace v. Curran
881 N.E.2d 792 (Massachusetts Appeals Court, 2008)
In re R.B.
98 N.E.3d 678 (Massachusetts Supreme Judicial Court, 2018)

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ELI PARISEAU, Counsel Stack Legal Research, https://law.counselstack.com/opinion/eli-pariseau-massappct-2026.