Court Finds that Evidence of Gang Membership Was Relevant in Massachusetts Murder Case

Recently, the Supreme Judicial Court issued an opinion in a Massachusetts murder case. The case arose after three individuals were murdered, and their dismembered bodies were found in plastic bags. The Commonwealth’s case hinged on the premise that the defendant and two others murdered the victims to prevent them from testifying against one of the accomplices. The parties were tried separately and convicted of three counts of first-degree murder.

Amongst several contentions, the defendant argued that evidence of his membership in the Aryan Brotherhood was impermissible. He contended that the evidence carried a risk of substantial unfair prejudice and outweighed any probative value. Specifically, he argued that the judge’s ruling permitting anatomical drawings, photographs of weapons and evidence of his membership in the Brotherhood was an abuse of discretion. In response, the Commonwealth alleged that the evidence was relevant and admissible. The court focused on the evidence implicating the parties in the murder.

Under the Massachusetts Rules of Evidence, the law prohibits the prosecution from introducing “prior bad act” evidence to illustrate a defendant’s bad character. However, the evidence is admissible for non-propensity purposes. Courts maintain a great deal of discretion when determining whether evidence is unfairly prejudicial to a defendant. Here, the Commonwealth argued that the evidence was properly admitted for two non-propensity-related reasons. First, the evidence shows how one of the accomplices induced another to help bury the victims’ remains; second, how the defendant’s admission to another member of the Aryan Brotherhood enhances the jailhouse informant’s credibility.

In this case, the court found that the testimony was probative because it was used to explain why one of the defendants cooperated with the plan and did not tell the police about what he had done. Secondly, evidence that the defendant and jailhouse informant were members of the Aryan Brotherhood show that it is more likely that the defendant truthfully admitted the cases’ details. Further, the evidence was not unduly prejudicial because the trial judge took steps to limit the testimony’s impact. He questioned each juror about whether a defendant’s affiliation with the Aryan Brotherhood would affect the juror’s ability to be impartial. Further, the judge dismissed jurors who stated that it would impact their ability. Moreover, the judge repeatedly provided instructions that membership in the Brotherhood was not illegal and not evidence of the defendant’s character. Ultimately, the court affirmed the defendant’s convictions.

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