The Massachusetts Supreme Judicial Court today concluded there was sufficient evidence to convict a Springfield man of first-degree murder, but nonetheless reduced the conviction to voluntary manslaughter. The name of the case is Commonwealth v. Vargas.
The victim’s wife was having an affair with the defendant. The victim served in the National Guard and in July of 2004 he left for an army base in New York to train to deploy to Iraq. As the victim left Massachusetts, he and his wife separated, but he left some handguns and other personal belongings at her apartment. After the victim moved, the defendant began staying at the wife’s apartment. A couple of months later, the victim called his wife to say he was returning to collect his belongings. One night, the victim burst into the wife’s apartment and began to physically attack her. The defendant emerged from the bedroom and the victim knocked him down and jumped on top of him. The defendant yelled for the victim’s wife to call the police and she left the apartment to summons help. When she returned, she found the victim lying on the couch and bleeding. The defendant had stabbed him eight times and he died during the ambulance ride to the hospital. The defendant argued at trial that he killed the victim in self-defense. The jury rejected the defendant’s self-defense argument and convicted him of first-degree murder. The trial judge sentenced the defendant to the mandatory life sentence.
The defendant appealed and argued the judge had committed a number of evidentiary mistakes. The Supreme Judicial Court ruled the trial had been fair but vacated the defendant’s murder conviction on a rarely used rule that allows for the reduction of a charge if it is “more consonant with justice.” The most famous case in which a verdict was reduced in this manner is Commonwealth v. Woodward. Defendant Louise Woodward was an English au pair who was charged with beating an eight-month-old baby to death in 1997. A jury convicted her of second-degree murder and the trial judge sentenced her to life in prison. However, the judge later ruled that a conviction for manslaughter, rather than murder, was more consonant with justice and he resentenced Woodward to the time she had served while awaiting trial (279 days). The Commonwealth appealed and the Supreme Judicial Court upheld the trial judge’s reduction of Woodward’s conviction. The Court cautioned, however, that trial judges should use their power to reduce verdicts sparingly. Judges have heeded the SJC’s warning and very rarely reduce murder convictions to manslaughter.
According to the SJC, this case presents the rare fact pattern that makes a verdict reduction appropriate. The trial evidence suggested the victim was the initial aggressor and was much larger than the defendant. The victim was trained in combat techniques and the defendant was scared of him. As the victim pounced on the defendant, the defendant urged the victim’s wife to call 911. The killing appears to have been committed in the heat of passion rather than as a result of malice. For all of these reasons, while the evidence legally supported the defendant’s murder conviction, the SJC determined a manslaughter conviction was more consonant with justice. The defendant’s case was remanded back to the superior court for resentencing.