Massachusetts Supreme Judicial Court Reverses Manslaughter Conviction Finding That Judge Improperly Excluded Evidence Supportive of Self-Defense Claim

Yesterday the Massachusetts Supreme Judicial Court issued its opinion in the case of Commonwealth v. Chambers. Chambers was tried in the Suffolk Superior Court for the death of Edward Quiles. The district attorney proved that in the winter of 2008 Chambers lived with the victim and another (Ceurvels) in an apartment in Boston. All three were drug users abusing Cocaine and Heroin. Ceurvels witnessed the incident and testified at trial to the following: The night before the killing Chambers and Quiles were injecting Heroin. They fell asleep around 4:00 a.m. the next day. They woke up to Quiles yelling about a missing gram of heroin. They went back to sleep again. Later that afternoon Quiles woke the other two again complaining about some missing heroin. Chamber and Quiles looked around the apartment for the drugs. Ceurvels left for a while. Ten minutes later Ceurvels returned to find Chambers and Quiles in “an all-out brawl”. Ceurvels then saw blood on the floor and heard Quiles yell to Chambers that Chambers had stabbed him. Ceurvels left the apartment and through another notified the police. He never saw a weapon. The police entered the home and found Quiles dead. The medical examiner testified that Quiles died from a stab wound to the neck.

Chambers was arrested. At the police station he stated that Quiles was high on drugs and that he had accused Chambers of stealing his drugs. He stated that Quiles produced the knife, punched him in the head and called one of his friends to come over and kill Chambers. Chambers also said that Quiles had threatened to stab him and would not let him leave the apartment.

Before the trial started the defense requested and obtained evidence of specific acts of violence committed by Quiles. The district attorney tried to exclude this material at trial. The judge agreed to permit Chambers to admit this evidence, specifically that in 2006 Quiles and others Assaulted and Robbed another individual. The collateral evidence is known as “Adjutant evidence”. Relying on this ruling the defense attorney mentioned this in his opening statement. During the trial, the judge changed her mind on the admissibility of the Adjutant evidence. In doing so she ruled that since the identity of the first aggressor was not an issue at trial Adjutant did not apply. The Supreme Judicial Court held this to be error. It concluded that Adjutant applies “where there is a dispute at trial as to who threatened or struck the first blow or as to who initiated the threat or use of deadly force”. The improper restriction on the use of the Adjutant evidence coupled with the judge’s failure to remedy defense counsel’s reference to this in his opening statement warranted a reversal of Chambers’ conviction.

This case proves what I have been telling clients for over twenty-five years. No case is hopeless. No matter what stage the proceedings are at there is a way for you to get some relief. If you need an Experienced Massachusetts Criminal Lawyer call us now at 617-263-6800 or send us an email. We know that we can help you with your case.