Massachusetts Court Reverses Defendant’s Assault Conviction Based on Admission of Friend’s Guilty Plea

Earlier this year, a state appellate court issued a written opinion in a Massachusetts assault case involving an interesting evidentiary issue. Specifically, the case required the court to determine if it was an error to admit the official criminal docket of the defendant’s friend whom he was with when he allegedly committed the assault. The docket indicated that the defendant’s friend pleaded guilty to a similar crime, involving the possession of a weapon. Ultimately, the court concluded that admission of the docket was a constitutional error that necessitated a new trial.

According to the court’s opinion, the defendant and a friend, Charles, were involved in an altercation with two other men. Initially, the defendant and Charles saw one of the men at a gas station, where the confrontation began. However, as the man drove from the gas station to a friend’s home, the defendant and Charles followed.

When the man parked in the driveway at his friend’s house, the defendant pulled behind. The defendant then got out and approached the driver’s side window of the man’s truck. At some point, the man rolled the window down slightly and the defendant pushed it down the rest of the way and struck him in the face. The man’s friend, who was sitting on the porch, ran down and tackled the defendant. Charles had a knife and, while this was going on, he got out of the car and threatened to kill both other men and to assault their family members.

The defendant was charged with the assault of the man inside the car, as well as one count of threatening to commit a crime. At trial, the defendant claimed that he was unaware that his friend Charles had gotten out of the car. In an effort to impeach the defendant, the prosecution introduced Charles’ criminal record, showing that he was convicted of assault with a weapon on the same day. The defendant was convicted, and appealed the court’s ruling allowing the admission of Charles’ criminal record into evidence.

On appeal, the court reversed the defendant’s conviction, finding that admitting Charles’ criminal record violated the defendant’s rights under the Confrontation Clause. The court explained that the defendant was denied the opportunity to question Charles about why he plead guilty. The court also noted that the introduction violated the general prohibition against hearsay. Thus, the court reversed the defendant’s conviction, ordering a new trial.

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