Massachusetts Supreme Judicial Court Upholds Plymouth Murder Conviction, but Orders Hearing to Determine if New Trial is Warranted

The Massachusetts Supreme Judicial Court today affirmed a defendant’s conviction for murdering a Plymouth man in his home 13 years ago, but ordered a superior court judge to hold a hearing to determine if the defendant is entitled to a new trial.  The name of the case is Commonwealth v. Holbrook. 

On the Monday after Thanksgiving in 2006, the victim was discovered dead in his home, lying face down in a pool of his own blood.  The medical examiner determined he had died as a result of a brain laceration and three skull fractures.  It appeared the victim had been struck in the head three times with a blunt instrument that had sharp edges.  His house had been ransacked and there was no money recovered from his person or his home (which was unusual, as the victim often carried large amounts of cash).  His computer had been submerged in water in the bathtub (and a subsequent forensic examination revealed it had been shut down the day before the body was found).  The victim’s pickup truck was also missing.  The defendant was a homeless man who had been hired to rake leaves in the victim’s yard a few days prior to the murder.  A man matching the defendant’s description was seen around the victim’s house and rummaging through his vehicle in the days prior to the victim’s body being found.  The day before the victim’s body was found, a man matching the defendant’s description was seen leaving the victim’s house in the victim’s truck (which was later seen on surveillance video at a local grocery store).  Meanwhile, around the time of the murder, the defendant was seen possessing large amounts of cash and staying in a motel room (which was unusual for him).

At trial, the defendant asserted he had not killed the victim and had last seen him three days prior to the discovery of the victim’s body.  The defendant argued the murder had been committed by the victim’s former boyfriend, Sean Meagher.  Meagher testified at trial that although he lived with the victim for two years and had slept in the same bed with him, they were not romantically involved.  He also said he had not seen the victim for a month prior to the murder and he only left his home the weekend after Thanksgiving (when the murder was committed) to grocery shop.  What the jury did not hear was that an independent witness saw Meagher at the victim’s house two days prior to the victim’s body being found, and a second independent witness told the police Meagher and the victim were lovers and Meagher had been emailing the victim in an attempt to extort him.  A Plymouth Superior Court jury convicted the defendant of first-degree murder, armed robbery, and larceny of a motor vehicle.  He filed a motion for a new trial, which was denied by the trial judge, and then appealed.

The SJC affirmed the conviction, but said the superior court judge committed error by not granting the defendant a hearing on his motion for a new trial.  The defendant made two assertions in his new trial motion – first that his trial attorney had not effectively presented a case that Meagher was the true killer, and second that the Commonwealth had committed prosecutorial misconduct by not turning over exculpatory evidence.  Exculpatory evidence is evidence that might be beneficial to a defendant’s case, and prosecutors are required to produce such evidence to criminal defendants.  In this case, the Commonwealth asserted there was “nothing of evidentiary value” found on the victim’s computer that had been submerged in the bathtub.  However, there were two emails written by the victim to Meagher that made it clear they had shared a romantic relationship.  These emails established Meagher was lying about the nature of their relationship and could have been used to impeach Meagher’s trial testimony.  The SJC ordered the case to be returned to the superior court so a judge can reconsider whether the defendant is entitled to a new trial.