Massachusetts Supreme Judicial Court Upholds Webster Murder Conviction

The Massachusetts Supreme Judicial Court today affirmed a defendant’s conviction for murdering his ex-girlfriend at her job in Webster in 2008.  The name of the case is Commonwealth v. Goddard. 

The defendant and the victim had dated for about two years and had lived together.  In 2007, the victim ended the relationship because the defendant had become jealous, believing the victim was having an affair with her boss.  The defendant became enraged when the victim threw him out of her house.  On January 28, 2008, the defendant traveled to the automotive shop where the victim worked.  The defendant forced his way into the victim’s office.  The victim and her boss were present and the defendant shot both of them.  He shot the victim in the neck and she died within a few minutes.  He shot the boss in the left arm.  The defendant attempted to continue shooting, but his gun misfired and he fled the scene.  As he was leaving, the defendant attempted to shoot another employee, but his weapon again misfired.  As he drove away, the victim called a law enforcement officer and admitted he shot multiple people.  He then drove to his sister’s house and convinced her to drive him to Worcester.  The defendant met up with a friend in Worcester and hung out at her house for about an hour and a half.  When the friend received a phone call that the cops were looking for her, the defendant ran away.  He was located and surrounded by police officers in a nearby field, where he was ultimately taken into custody and charged with first-degree murder.  At his trial, he never denied shooting the victim, but said he was not criminally responsible (the insanity defense).  The jury convicted him and he appealed.

The sole issue on appeal was the propriety of the Commonwealth’s expert’s testimony.  The prosecution called a psychiatrist to rebut the defendant’s claim that he was insane at the time he shot the victim and her boss.  The psychiatrist testified that it was her opinion the defendant’s conduct on the date of the killing was planned and he was participating in “goal-directed behaviors.”  The defendant argued that the psychiatrist’s testimony constituted an improper opinion about the ultimate issue in the case (whether the defendant had premeditated the shooting).  The rule in Massachusetts is that an expert cannot offer an opinion about whether a defendant is guilty or innocent.  However, opinions that “touch on” the ultimate issues in a case are permitted.  The Supreme Judicial Court reasoned that the psychiatrist’s testimony here was proper, because it was related not to whether the defendant’s conduct was premeditated (which is an element of first-degree murder), but rather whether he was criminally responsible.  The Court also said even if admission of the psychiatrist’s testimony was error, it was harmless because evidence of his premeditation was overwhelming (including evidence that he searched the Internet for “How do I get away with murder”).  Accordingly, the defendant was properly convicted and he will spend the rest of his life in prison.