Commonwealth v. Steadman, SJC-11553

CourtUnited States State Supreme Judicial Court of Massachusetts
Citation489 Mass. 372,183 N.E.3d 412
Docket NumberSJC-11553
Decision Date25 March 2022

489 Mass. 372
183 N.E.3d 412



Supreme Judicial Court of Massachusetts, Norfolk.

Argued November 5, 2021.
Decided March 25, 2022.

Brian A. Kelley, for the defendant.

Stephanie Martin Glennon, Assistant District Attorney, for the Commonwealth.

Present: Budd, C.J., Cypher, Kafker, Wendlandt, & Georges, JJ.


489 Mass. 373

A jury convicted the defendant, Scott Steadman, of murder in the first degree based on both deliberate premeditation and extreme atrocity or cruelty for the death of Ronald Pratt, who was found in his tent at a campsite with forty-six stab wounds. The defendant was also convicted of two counts of assault and battery by means of a dangerous weapon for altercations with two individuals who shared the campsite with Pratt. The defendant now appeals from his convictions and from the denial of two postconviction motions, one requesting forensic testing pursuant to G. L. c. 278A and the other for an advance of expert fees.

As to his direct appeal, the defendant first argues that the trial judge erred by admitting joint venture hearsay evidence where there was no joint venture, or, in the alternative, where the statement was not in furtherance of the joint venture. Second, the defendant argues that he was entitled to a mistrial when, midtrial, he first learned that one of the Commonwealth's identified experts had performed an additional test on a bloody footprint in evidence. Third, he claims that the trial judge erred by excluding certain third-party culprit evidence. Finally, the defendant argues that the jury charge should not have included a consciousness of guilt instruction.

We discern no reversible error in our review of the defendant's direct appeal. Having thoroughly examined the record, we also

489 Mass. 374

conclude that there is no reason to grant relief under G. L. c. 278, § 33E.

Although we affirm the defendant's convictions, we consider his motions related to postconviction forensic testing separately, as they are part of a process that is "separate from the trial and any subsequent proceedings challenging an underlying conviction." Commonwealth v. Clark, 472 Mass. 120, 121-122, 34 N.E.3d 1 (2015). Our review reveals that the defendant's motion for expert fees was premature and thus properly denied. We also conclude, however, that his motion requesting forensic analysis meets the modest threshold requirements of G. L. c. 278A, § 3. We therefore reverse its dismissal and remand to the trial court for further proceedings consistent with this opinion.

Background. We summarize the facts as the jury could have found them, reserving certain details for our discussion of specific issues.

At the time of his death, Ronald Pratt resided in a tent at a campsite in Weymouth.

183 N.E.3d 419

He shared the campsite with a married couple, Kristen Fuller and Robert Fuller, who occupied their own nearby tent.1 On the morning of July 18, 2009, Pratt got into an argument with Derek Royal, a frequent visitor to the campsite, about Royal allegedly cutting down Pratt's marijuana plants. Royal left, angry. That afternoon the defendant, Timothy Estabrooks, and William Lambert drove to the campsite in the defendant's vehicle to visit Pratt. The group drank alcohol, smoked marijuana, and played darts and cards. Later in the afternoon the defendant and Estabrooks drove Lambert home and then returned to the campsite. At some point Kristen felt unwell and retired to her tent to sleep.

Kristen awoke to shouting: an altercation between the defendant, Pratt, and Estabrooks was in progress. She heard the defendant say to Pratt, "Don't disrespect me like that," and heard Pratt fall to the ground. Robert got between the defendant and Pratt; in response, the defendant punched him, knocking him down. The defendant and Estabrooks, both wearing sneakers, then began to kick Robert in the face. When Kristen tried to intervene, the defendant pushed her down and hit her in the face with a lawn chair before resuming his assault on Robert. The defendant warned the Fullers to stay on the ground, or he was "going to get

489 Mass. 375

his gun." Shortly thereafter he and Estabrooks left the campsite. Kristen tended to Robert's bloodied face, and then they and Pratt, who appeared uninjured from the melee, retired to their respective tents for the night. The Fullers changed their clothes, putting their bloody laundry into a plastic bag.

Meanwhile, the defendant and Estabrooks returned to Lambert's nearby apartment, arriving shortly before 11 P.M. As they continued to drink and watch television, the defendant told Lambert that he had been in a fight with Pratt, and that they "beat [Robert's] ass" when the Fullers tried to intervene. The defendant asked Lambert if he still had a particular Buck 119 hunting knife, and after Lambert retrieved the knife, the defendant took it, a sheath, and a belt from Lambert, saying that he wanted to return to the campsite by himself. He then departed the apartment alone.

Back at the campsite, Robert was awakened by a man yelling just outside his tent. The tent was shaken, and Robert saw a knife blade slice into the tent door as a male voice said, "You're next, motherfucker. I got a gun." Robert did not get out of the tent at that time.

At approximately 2 A.M. , Weymouth Police Sergeant Kevin Malloy was on patrol and observed the defendant walking, shirtless, down a street near the campsite. As he approached the defendant, who was at that point in front of a closed fast food restaurant, Malloy noticed that the defendant had a significant amount of dried blood on his hands. When Malloy asked what happened, the defendant replied that he had fallen off a bicycle and was walking to his friend's apartment, giving Lambert's address. Malloy could see no injuries on the defendant, nor did he see any bicycle. After the defendant assured Malloy that he could make it to Lambert's, he continued on his way.

At some point in the early morning hours, Lambert was awakened by the defendant returning to his apartment. When Lambert asked why he was there so late, the defendant replied that "the cops [were] after [him]," and that he had "hucked" Lambert's knife away "somewhere around

183 N.E.3d 420

[the fast food restaurant]." Lambert continued to press the defendant about what was going on, and the defendant ultimately stated, "Just say you won't see Ron around here anymore."

The defendant removed his clothes and sneakers, put them in a plastic bag, and asked Lambert to put them "in the incinerator." Lambert took the bag and put it in his own car's trunk because, although his apartment building did have an incinerator, he knew

489 Mass. 376

it was not functioning. The defendant fell asleep on Lambert's futon.

Several hours later, the defendant and Estabrooks left Lambert's apartment and traveled to the home of Karen Chase in Brockton, arriving at approximately 8 A.M. Chase was Estabrooks's former mother-in-law, and he was living with her at the time. Chase saw the defendant use her hose to wash off his body and shoes on her back porch, which Estabrooks explained was because they had just come from the beach. She agreed to let Estabrooks use her washing machine and dryer. Chase testified that, during their interaction, Estabrooks showed her a shirt with a ten-inch circle of blood on it and said, "I think Scott's in trouble." The defendant and Estabrooks left Chase's home together around 11 A.M.

At the campsite, Kristen awoke that morning to the sound of Robert shouting. As she emerged from her tent, she noticed a tear in its screen that hadn't been there when she had gone to sleep. She found her husband outside and walked over to Pratt's tent, which had had its door ripped open. Inside, Pratt lay on his side in a pool of blood, dead.

Kristen changed her clothes, packing them into the couple's laundry bag, and she and Robert left the campsite.2 The two split up. At 8:36 A.M. , Kristen called 911 from a nearby pay telephone, and when first responders arrived minutes later, she led them to the campsite. Robert, meanwhile, walked in a different direction, wishing to avoid police contact due to outstanding warrants for failure to register as a sex offender. He was located and arrested on those warrants several hours later, and was ultimately sent to a hospital for treatment for his head injuries.

That afternoon the police questioned Lambert at his apartment. He became distraught upon learning that they were investigating Pratt's death. During their conversation, Lambert received a telephone call from the defendant, who stated he was downstairs. Lambert led the police to the rear of his building, where they found the defendant and arrested him, as well as Estabrooks, who was sleeping in the front seat of the defendant's nearby vehicle. Two pairs of sneakers were recovered from the vehicle, both of which had what appeared to be bloodstains on them. No weapons were found in searches of the defendant's vehicle, the campsite...

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4 cases
  • Commonwealth v. Ramos, SJC-12678
    • United States
    • United States State Supreme Judicial Court of Massachusetts
    • 28 Noviembre 2022
    ...not that it "would have had any effect on the underlying conviction" (emphasis in original). 198 N.E.3d 445 Commonwealth v. Steadman, 489 Mass. 372, 389, 183 N.E.3d 412 (2022), quoting Wade, 467 Mass. at 508, 5 N.E.3d 816 (discussing parallel materiality requirement in § 3 [b ] [4]). Here, ......
  • Commonwealth v. Ramos, SJC-12678
    • United States
    • United States State Supreme Judicial Court of Massachusetts
    • 28 Noviembre 2022
    ...claim,[7] not that it "would have had any effect on the underlying conviction" 16 (emphasis in original). Commonwealth v. Steadman, 489 Mass. 372, 389 (2022), quoting Wade, 467 Mass. at 508 (discussing parallel materiality requirement in § 3 [b] [4]). Here, the defendant has done so. The wi......
  • Commonwealth v. MacCormack, SJC-13022
    • United States
    • United States State Supreme Judicial Court of Massachusetts
    • 9 Mayo 2023
    ...insofar it tends to show that another person had the motive, intent, opportunity to commit the offense. Commonwealth v. Steadman, 489 Mass. 372, 383 (2022), citing Commonwealth v. Silva-Santiago, 453 Mass. 782, 800-801 (2009). Such evidence "must have a rational tendency to prove the issue ......
  • Commonwealth v. Acevedo, SJC-13131
    • United States
    • United States State Supreme Judicial Court of Massachusetts
    • 12 Julio 2023
    ...the Commonwealth to prove beyond a reasonable doubt that the third-party culprit did not commit the crime.'" Commonwealth v. Steadman, 489 Mass. 372, 383 (2022), quoting Silva-Santiago, supra. We conclude that the judge properly excluded the proffered third-party culprit evidence consisting......

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