Commonwealth v. Taylor

Summary

The Supreme Judicial Court of Massachusetts reviewed Rodrick James Taylor's conviction of murder in the second degree. The court held that the trial judge did not abuse discretion in denying Taylor's motion to dismiss for lack of a speedy trial under Mass. R. Crim. P. 36, although it modified the treatment of delays caused by motions to compel mandatory discovery under Mass. R. Crim. P. 14. The court also concluded that improper remarks in the prosecutor's closing argument did not constitute reversible error.

Holdings

1. The Superior Court did not abuse its discretion in denying Taylor's motion to dismiss because, although 614 calendar days elapsed before the motion, Taylor acquiesced in or benefited from at least 388 days of delay, exceeding the 249 days the Commonwealth was required to justify.
2. When the Commonwealth fails to produce mandatory discovery under Mass. R. Crim. P. 14(a)(1), the time required to resolve a defendant's motion to compel or for sanctions under rule 14(a)(1)(C) is not automatically excluded from the rule 36 speedy-trial calculation. The judge must determine case by case whether the delay should count against the Commonwealth.
3. The prosecutor's characterization of the defense theory as a 'bald-face lie' and invocation of the jurors' oath were improper, but the remarks did not constitute prejudicial error requiring reversal.

Questions Presented

1. Whether the Superior Court abused its discretion by denying Taylor's motion to dismiss under Mass. R. Crim. P. 36 for failure to bring him to trial within twelve months.
2. Whether delays caused by the Commonwealth's failure to provide mandatory discovery under Mass. R. Crim. P. 14 should automatically be excluded from the rule 36 speedy-trial calculation.
3. Whether improper remarks in the prosecutor's closing argument required reversal of Taylor's conviction and a new trial.

Disposition

affirmed