Massachusetts Supreme Judicial Court Reverses Murder Conviction Due to Insufficient Evidence
The Supreme Judicial Court of Massachusetts reversed Jean Carlos Lopez’s murder conviction because the evidence was insufficient to establish beyond a reasonable doubt that Lopez knowingly participated in the killing with the requisite intent.
When Lopez and Erving Cruz arrived at a convenience store around 11:30 p.m., Lopez’s brother Etnid was chasing Tigan Hollingsworth in the parking lot with a knife. Cruz shouted to Etnid, “Is that him? Is that him? Get him. Get him.” Cruz joined the chase.
Surveillance video showed Etnid was wearing a white T-shirt, Cruz was wearing a black tank top and black pants, Hollingsworth was wearing a black jacket with gold lettering, and Lopez wore a light-blue sweatshirt. Also present in the parking lot were Jared Brown-Garnham wearing dark clothes, Kayla Lawrence (Etnid’s girlfriend), and Michelle Torrey. Hollingsworth ran out of the parking lot and down the street. Matthew D’Alessandro and Brittany Machado observed Hollingsworth being chased by two men — one wearing a white T-shirt (presumably Etnid) and the other had on a black tank top and black pants (presumably Cruz).
Hollingsworth ran up a driveway and scaled a chain-link fence and was in a nearby backyard when the two men caught him. The two men hit Hollingsworth repeatedly, then jumped the fence and fled. D’Alessandro later testified that the two men chasing Hollingsworth down the street were the same two men seen chasing him in the surveillance video (Etnid and Cruz). After the attackers fled, D’Alessandro and Machado tended to Hollingsworth until police arrived.
Hollingsworth had been repeatedly stabbed in the lungs and head, and blood pooled on the ground beneath his body. Janet Dinneen testified that she saw three men attack Hollingsworth in the backyard - one attacker wearing white and the other two wearing dark clothing. Lawrence testified that Etnid, Cruz, Garnham, and Lopez chased Hollingsworth down the street and into a driveway. She saw the four men fighting with Hollingsworth in the driveway. Torrey then drove up and called for everyone to get into her car. Etnid, Garnham, and Lawrence got into Torrey’s vehicle and left. She said she last saw Hollingsworth alive and groaning in pain on the ground.
Lawrence further testified that she didn’t enter the back yard and that after leaving the scene, she and Garnham hid a knife in a storm drain. The knife was introduced at trial as the murder weapon. The Commonwealth’s theory was that Etnid, Cruz, and Lopez stabbed Hollingsworth in the back yard. Etnid then left with Lawrence and Garnham in Torrey’s vehicle while Cruz and Lopez jumped back over the fence and returned to Lopez’s vehicle. The jury convicted Lopez, and he appealed, arguing, inter alia, the evidence was insufficient to support his conviction of murder in the first degree as a joint venturer.
The Supreme Judicial Court observed that to sustain the conviction, “the Commonwealth must prove beyond a reasonable doubt that the defendant ‘knowingly participated in the commission of the crime charged, alone or with others, with the intent required for the offense.’” Commonwealth v. Rakes, 82 N.E.3d 403 (Mass. 2017). Although reviewing claims of insufficient evidence required the Court to examine the evidence in the light most favorable to the prosecution, Commonwealth v. Deane, 934 N.E.2d 794 (Mass. 2010), the Court “must find that there was enough evidence that could have satisfied a rational trier of fact of each element beyond a reasonable doubt.” Commonwealth v. Latimore, 393 N.E.2d 370 (Mass. 1979). And even though a jury is permitted to draw rational inferences from the evidence, “no essential element of the crime may rest in surmise, conjecture, or guesswork.” Commonwealth v. Kelley, 268 N.E.2d 132 (Mass. 1971).
Lawrence’s testimony was the only evidence implicating Lopez in the attack on Hollingsworth. She said she saw the men fighting in the driveway. But the stabbing couldn’t have occurred in the driveway because no blood was found at that location. Another possibility was that after Etnid, Garnham, and Lawrence had left the scene with Torrey, Hollingsworth managed to scale the fence, and then Lopez and Cruz stabbed him in the backyard. But this was contradicted by the other witnesses’ descriptions of the attackers in the backyard, i.e., D’Alessandro and Machado described Cruz and Etnid as the attackers in the backyard while Dinneen saw a third attacker in dark clothes. None saw Lopez in a light blue sweatshirt. Further, this would require the jury to engage in speculation or conjecture, especially regarding how Hollingsworth could have been stabbed in the backyard with the knife that had already been taken from the scene with Lawrence and Garnham.
The Court concluded there was insufficient evidence to prove Lopez guilty of murder beyond a reasonable doubt under either scenario. Accordingly, the Court reversed the conviction, set aside the verdict, and remanded to the superior court with instructions to enter a judgment of not guilty. See: Commonwealth v. Lopez, 140 N.E.3d 427 (Mass. 2020).
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Related legal case
Commonwealth v. Lopez
|Cite||140 N.E.3d 427 (Mass. 2020)|
|Level||State Supreme Court|
|Appeals Court Edition||F.3d|