Summary
This Massachusetts Supreme Judicial Court opinion addresses a direct appeal following the conviction of Philip Chism for first-degree murder, aggravated rape, and armed robbery. The defendant challenged multiple trial court rulings, including the exclusion of sMRI brain scan evidence, restrictions on expert psychiatric testimony, discovery disputes regarding psychological testing data, and the admission of prosecution expert testimony based on a suppressed confession. After reviewing the record, the court affirmed the convictions and declined to reduce the verdict or order a new trial.
Topics
Practice areas
Questions Presented
- Whether the trial judge erred in excluding sMRI brain‑scan expert testimony.
- Whether the judge erred in prohibiting the defendant's expert from testifying to hearsay statements.
- Whether the prosecutor improperly cross‑examined defense experts on irrelevant topics.
- Whether the judge erred in ordering disclosure of raw psychological testing data from non‑testifying experts.
- Whether the Commonwealth's expert should have been precluded after reviewing a suppressed videotaped confession.
- Whether the jury should have been instructed on adolescent brain development.
- Whether the Commonwealth proved the aggravated rape and armed robbery elements.
- Whether the inevitable‑discovery doctrine justified denial of a motion to suppress physical evidence.
- Whether the prosecutor’s closing argument exceeded permissible bounds.
- Whether the trial judge abused discretion in denying a change of venue.
- Whether the forty‑year sentences for the non‑homicide convictions violated the proportionality requirement of art. 26 of the Massachusetts Declaration of Rights.
Holdings
- The trial judge properly excluded the sMRI expert testimony because its probative value was substantially outweighed by the danger of unfair prejudice and it failed the Daubert‑Lanigan gatekeeping requirements.
- The judge correctly excluded the defendant’s statements from expert testimony on direct examination because an expert may not testify to the substance of inadmissible hearsay.
- The trial judge abused discretion by ordering disclosure of raw data from non‑testifying experts; however, the error was not prejudicial.
- The denial was proper; the evidence would have been inevitably discovered through the police inventory policy.
- The forty‑year sentences for the aggravated rape and armed robbery convictions do not violate the proportionality requirement; the court affirmed the sentencing.
Key quotations
“The decision to exclude expert testimony rests in the broad discretion of the judge and will not be disturbed unless the exercise of that discretion constitutes an abuse of discretion or other error of law.” (467 Mass. 416)
Factual background
In October 2013 a fourteen‑year‑old student, Philip Chism, entered his math teacher's classroom and later her bathroom, where he raped, stabbed, and murdered her. He subsequently stole her credit cards, disposed of evidence, and was apprehended after a police encounter. The trial court convicted him of murder, aggravated rape, and armed robbery.
Procedural history
The defendant was convicted of first‑degree murder, aggravated rape, and armed robbery in the Superior Court. He appealed on eleven grounds, including exclusion of expert testimony, hearsay, discovery orders, suppression of evidence, venue, and sentencing. The Supreme Judicial Court reviewed the trial judge's discretionary rulings for abuse of discretion and affirmed the convictions.