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Law School Case Brief

Commonwealth v. Zagranski - 408 Mass. 278, 558 N.E.2d 933 (1990)

Rule:

The state-of-mind exception to the hearsay rule admits relevant evidence of the victim's state of mind of which the defendant was aware. Such a statement is not admissible in evidence unless the trier of fact is warranted in finding that the defendant had been aware of the victim's state of mind. Such a statement is not admissible to prove the facts stated, but only the declarant's state of mind. In certain instances, a voir dire hearing concerning the admissibility of the proffered state-of-mind evidence would aid the judge. Preferably, the judge should tell the jury of the limited purpose for which such evidence is admitted, at the time it is admitted.

Facts:

Defendant and Michael Molin, owner of a hotel, were in discussion regarding the proposed sale of Molin’s hotel to the former. Thereafter, Molin was killed. The investigating police officer issued search warrants authorizing the search of the interior of a motor vehicle rented by the defendant and the search of storage space rented by the defendant. Affidavits of the police officer revealed that a teenage boy said he that he helped a man with a shotgun load a wounded man into the trunk of an automobile; the teenage boy then identified the defendant as the person he helped. Upon searching the motor vehicle and the storage space, Molin’s body was found. Personal items of the defendant, including his shotgun, were also found there. During trial, testimonies regarding the defendant’s scheme to lure the victim into a sale, and kill the latter without paying, were admitted by the trial court as an exception to the hearsay rule. Consequently, defendant was charged and convicted of first-degree murder. Defendant challenged the admission of evidence.

Issue:

Were the evidence presented by Commonwealth improperly admitted by the trial court, and if so, did they prejudice the case of the defendant?

Answer:

Yes; No.

Conclusion:

While the Court noted that it was error to admit under the state-of-mind exception to the hearsay rule the testimonies regarding the defendant’s intent to kill the victim, the Court held that the error did not prejudice the defendant’s case as there were overwhelming evidence of defendant’s guilt.

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