Commonwealth v. Gallarelli

Massachusetts Supreme Judicial Court
502 N.E.2d 516, 399 Mass. 17 (1987)

ELI5:

Rule of Law:

When a prosecutor fails to disclose exculpatory evidence following a specific defense request (such as a request for "scientific reports"), a new trial is required if the evidence provides a substantial basis for claiming materiality exists. A request is considered specific if it provides the prosecution with notice of the defendant's interest in a particular piece of evidence relevant to the crime charged.

Facts:

At a Boston nightclub, Stephen W. Travis was bumped from behind by the defendant.
Travis turned and pushed the defendant away.
The defendant threw a punch at Travis, who responded by punching the defendant, knocking him to his knees.
From a kneeling position, the defendant lunged upward with his hand toward Travis's stomach.
Travis then saw blood staining his shirt and realized he had been stabbed.
Police arrived within minutes, and one of Travis's friends identified the defendant inside the club.
After a chase and a violent struggle, police arrested the defendant and found a knife with a four-inch blade in his trousers.

Procedural Posture:

The Commonwealth and the defendant submitted a pretrial conference report in which the Commonwealth agreed to provide the defendant with exculpatory evidence, including "police reports" and "scientific reports."
At a jury trial in the trial court, the defendant was convicted of assault and battery by means of a dangerous weapon.
During the trial, the defendant's motions to strike testimony about the knife (which was lost) and to dismiss the case were denied by the trial judge.
After his conviction, the defendant's new counsel discovered the existence of a police crime lab report showing no blood on the knife.
The defendant filed a motion for postconviction relief, seeking a new trial on the grounds that the prosecution had suppressed exculpatory evidence.
The trial judge denied the defendant's motion for a new trial.
The defendant appealed the denial of his motion for a new trial to this court.

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Issue:

Does the Commonwealth's failure to disclose a laboratory report showing no blood on the alleged weapon violate the defendant's constitutional rights and require a new trial, when the defendant made a pretrial request for "scientific reports"?

Opinions:

Majority - Liacos, J.

Yes, the Commonwealth's failure to disclose the laboratory report requires a new trial. The pretrial agreement for the prosecution to provide "scientific reports" constituted a specific request for the lab report on the knife. When a specific request is made for exculpatory evidence, the standard for materiality is lower; the defendant need only show a 'substantial basis for claiming materiality exists.' Here, the eyewitness testimony regarding the stabbing was equivocal, with some witnesses not seeing a knife and the victim himself being unsure. A scientific report showing no blood on the knife found on the defendant is highly material and prejudicial in this context, as it directly undermines the prosecution's theory that this was the weapon used. The court rejected the trial judge's finding that defense counsel made a tactical decision not to pursue the report, finding it illogical to prefer arguing from an absence of evidence over using a concrete, exculpatory police report. Therefore, the suppression of this material evidence, following a specific request, warrants a new trial.

Analysis:

This decision clarifies the standard for what constitutes a "specific request" for exculpatory evidence under Massachusetts law, holding that a request for a category of documents like "scientific reports" is specific enough to put the prosecution on notice for relevant items within that category. The court's explicit rejection of the unified federal materiality standard from United States v. Bagley is significant, as it preserves a more defendant-protective, two-tiered standard in Massachusetts based on the specificity of the discovery request. This creates a divergence from federal due process jurisprudence and reinforces a prosecutor's duty to respond diligently to specific discovery agreements.

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