Commonwealth v. Rintala
| Citation | 174 N.E.3d 249,488 Mass. 421 |
| Decision Date | 27 September 2021 |
| Docket Number | SJC-12310 |
| Parties | COMMONWEALTH v. Cara L. RINTALA. |
| Court | United States State Supreme Judicial Court of Massachusetts |
The following submitted briefs for amici curiae:
Chauncey B. Wood, Boston, for the defendant.
Steven E. Gagne, Assistant District Attorney (Jennifer Handel Suhl, Assistant District Attorney, also present), for the Commonwealth.
Peter R. De Forest, Brooke W. Kammrath, Peter A. Pizzola, & John A. Reffner, pro se.
M. Chris Fabricant & Tania Brief, of New York, & Stephanie Roberts Hartung, for New England Innocence Project & another.
Katherine H. Judson, of Wisconsin, Anthony D. Mirenda, Neil Austin, Boston, & Rachel L. Davidson, for Center for Integrity in Forensic Science.
Present: Budd, C.J., Lowy, Cypher, Kafker, & Georges, JJ.
In 2016, a jury convicted the defendant of murder in the first degree for the murder of her spouse, Annamarie Rintala (victim). On appeal, the defendant challenges the admission of expert testimony as to the victim's time of death as well as expert testimony related to the time and manner in which paint was either poured or spilled on, under, and around the victim in the basement where the victim was found. The defendant also argues that there were errors requiring reversal related to the denial of her motion for a required finding of not guilty, the admission of evidence of prior misconduct, the judge's sua sponte instruction on consciousness of guilt, and the Commonwealth's closing argument. Finally, she argues that the retrial as well as the manner in which the Commonwealth presented its evidence at the third trial violated her constitutional rights.
We conclude that the admission of the expert testimony as to the timing and manner of application of paint in the basement was error. Because the error was prejudicial, we vacate the judgment entered against the defendant.1
1. Background. a. Facts. We briefly summarize the facts that the jury could have found at the defendant's trial, reserving details for our discussion of the legal issues.
On March 29, 2010, the defendant, a paramedic, returned to the home she shared with the victim in Granby at around 7 P.M. Shortly after entering the home, she saw the victim at the bottom of the stairs to the basement. The defendant initially only saw the victim's feet in the basement. Before going down to check on the victim, the defendant first brought their daughter and their dog to a neighbor and asked the neighbor to call 911. When first responders arrived, they found the defendant in the basement with the victim. Paramedics quickly determined that the victim was dead, and several members of the Granby police department brought the defendant upstairs. She spoke briefly with an officer at the scene before going to the Granby police station to speak with a State police detective working with the office of the district attorney for the northwestern district.
Various members of the State police responded to the scene and initiated an investigation. They extensively photographed the scene and collected physical evidence. Investigators recovered a container of paint from the floor near the body.2 When first responders had arrived, they observed paint all over the defendant, the victim, and the basement floor. The two paramedics and the first two police officers on scene offered various descriptions of the paint, each generally describing the paint as white, wet, and shiny. The victim had twenty-three distinct bruises all over her body, all of which appeared recent or fresh. These included multiple blunt injuries to the victim's head. The victim also had wounds around her neck, and the medical examiner concluded that the cause of death was manual strangulation.
Over the course of two interviews with the State police, the defendant provided a timeline of her activity on the date of the homicide. The defendant told detectives that she and the victim had been arguing the night before, as the victim had been upset about the defendant socializing with a male friend at home while the victim was at work.3 The defendant said that she left the house sometime around 3 P.M. on the day of the homicide. After leaving the house, the defendant went to a number of different locations.4 She eventually went to the Holyoke Mall, where she was identified on surveillance video footage just before 5 P.M. 5 From there, the defendant stopped at a restaurant around 5:47 P.M. The defendant did not enter the restaurant; instead, surveillance video footage shows her truck near the rear of the parking lot. From the video recording, it appears that the defendant threw several items in a trash can in the parking lot before driving away within one to two minutes of entering the parking lot. Three rags were later recovered from the trash can, one of which contained a "faint" bloodstain.6 After leaving the parking lot, the defendant then drove to a nearby grocery store, arriving just before 6 P.M. She purchased a few items and left the store at 6:19 P.M. She then drove to another restaurant that was approximately five miles away before returning home.
Throughout the time she was away in the afternoon, the defendant sent the victim text messages, attempted to call her multiple times, and left her several voicemail messages. The police recovered the victim's cell phone, which included the messages from the defendant and a significant number of text messages and calls, with the last outgoing communication occurring at 12:21 P.M. During her first interview on the night of the homicide, the defendant permitted the detectives to perform a brief visual search of most of her body.7 The Commonwealth's theory at trial was that the defendant and the victim had an acrimonious, at times violent, marriage, culminating with the defendant strangling the victim on March 29. The Commonwealth argued that the defendant engaged in a scheme designed to cover up her involvement in the homicide by driving around all afternoon, disposing of evidence, and attempting to communicate with the victim to demonstrate that she believed the victim was alive at the time of the calls. The defendant then intentionally poured the paint on the body and lifted the body onto herself before the police arrived to make the crime more difficult to investigate.
b. Procedural history. The defendant was indicted in October 2011. She was tried in early 2013 and again in early 2014. Both trials ended in mistrials because of hung juries. The Commonwealth tried the defendant a third time in September and October of 2016, and the defendant was convicted of murder in the first degree. At the third trial, the Commonwealth introduced for the first time the testimony of David Guilianelli, a quality engineer at the company that manufactured the paint found at the crime scene. Guilianelli provided expert testimony, based on his own experiments, explaining that the paint found at the crime scene was poured deliberately and not spilled and that the paint was poured no more than four hours before photographs were taken of the crime scene just after 9 P.M. The defendant filed a motion for a new trial in March 2019, which was denied. This appeal followed.
2. Discussion. On appeal, the defendant brings a number of claims related to (1) the admission of expert testimony, (2) the denial of her motion for a required finding of not guilty, (3) the admission of evidence of prior misconduct, (4) the judge's sua sponte instruction on consciousness of guilt, (5) the Commonwealth's closing argument, and (6) her due process rights. We address each argument in turn.
a. Expert testimony. The defendant contends that the trial judge erred in admitting the expert testimony of the medical examiner, Dr. Joann Richmond, as to the time of death.8 The defendant also challenges the admission of testimony from Guilianelli, the Commonwealth's paint expert. We address each challenge.
i. Legal background. We begin with the legal standards governing expert testimony. "We review a judge's determination to admit or exclude expert testimony ... for an abuse of discretion." Commonwealth v. DiCicco, 470 Mass. 720, 729, 25 N.E.3d 859 (2015). The defendant must therefore demonstrate that the judge made "a clear error of judgment in weighing the factors relevant to the decision, such that the decision falls outside the range of reasonable alternatives" (quotation and citation omitted). L.L. v. Commonwealth, 470 Mass. 169, 185 n.27, 20 N.E.3d 930 (2014). Given that the defendant moved to exclude the challenged testimony prior to trial and objected to the testimony during trial, she need only demonstrate that any error was prejudicial to warrant reversal. See Commonwealth v. Rosa, 468 Mass. 231, 239, 9 N.E.3d 832 (2014).
For expert testimony to be admissible, the proposed witness must be qualified as an expert to testify to a specific subject matter. See Mass. G. Evid. § 702 (2021). " ‘The crucial issue,’ in determining whether a witness is qualified to give an expert opinion, ‘is whether the witness has sufficient "education, training, experience and familiarity" with the subject matter of the testimony.’ " Commonwealth v. Frangipane, 433 Mass. 527, 533, 744 N.E.2d 25 (2001), quoting Commonwealth v. Richardson, 423 Mass. 180, 183, 667 N.E.2d 257 (1996). "Testimony ‘on matters within the witness's field of expertise is admissible’ when the testimony concerns matters beyond the common knowledge of the jurors and will aid the jurors in reaching a decision" (emphasis in original). Frangipane, supra, quoting Commonwealth v. Dockham, 405 Mass. 618, 628, 542 N.E.2d 591 (1989). At the same time, however, "a judge's discretion can be abused when an expert witness is permitted to testify to matters beyond an area of expertise or competence." Frangipane, supra.
In addition to whether the proposed expert is qualified, the judge must also determine that the expert testimony is sufficiently reliable to reach the jury. As the...
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