Commonwealth v. Piantedosi

Summary

The Massachusetts Supreme Judicial Court affirmed Christopher Piantedosi's convictions for murder in the first degree and malicious destruction of property. The court rejected challenges concerning expert testimony about hearsay statements underlying a mental-health opinion, testimony about what drove the defendant's conduct, and the omission of an instruction regarding the potential consequences of a verdict of not guilty by reason of insanity. The court also declined to reduce the murder conviction under its extraordinary review authority pursuant to G. L. c. 278, § 33E.

Holdings

1. An expert may rely on facts or data not admitted in evidence if they are independently admissible and a permissible basis for the opinion, but the expert may not testify on direct examination to the substance or contents of that otherwise unadmitted information.
2. A qualified expert may testify in medical or psychological terms that mental disease or defect did not drive the defendant's conduct and may identify other emotions as motivating the conduct, so long as the expert does not opine directly on guilt or criminal responsibility.
3. The Mutina instruction in the 2013 Model Jury Instructions on Homicide accurately stated Massachusetts law, and the judge did not err by failing to add the later Chappell language expressly stating that commitment could last for life.
4. After reviewing the entire record, the court found no reason to order a new trial or reduce the first-degree murder conviction to a lesser degree of guilt.

Questions Presented

1. Whether the trial judge improperly excluded, on direct examination of the defense psychiatrist, hearsay statements the defendant made during a forensic interview that formed part of the basis for the psychiatrist's opinion.
2. Whether the Commonwealth's psychiatrist improperly testified that anger, sadness, and rage, rather than mental disease or defect, drove the defendant's behavior.
3. Whether the judge's instruction concerning the consequences of a verdict of not guilty by reason of lack of criminal responsibility was legally insufficient because it did not expressly state that psychiatric commitment could last for life.
4. Whether the Supreme Judicial Court should reduce the first-degree murder conviction under its extraordinary review authority pursuant to G. L. c. 278, § 33E.

Disposition

affirmed