Commonwealth v. Rhoades

379 Mass. 810, 401 N.E.2d 342 (1980)



In reviewing the denial of a motion for directed verdict, the court considers only the evidence introduced up to the time the commonwealth rested its case. The court must determine whether the commonwealth's evidence, considered in its light most favorable to the commonwealth, was sufficient to permit the jury to infer the existence of the essential elements of the crime charged, and to bring minds of ordinary intelligence and sagacity to the persuasion of guilt beyond a reasonable doubt. Finally, such evidence must exist in regard to each element of the crime with which the defendant was charged.


Defendant was convicted of arson for setting a fire in an apartment. He was convicted of second degree murder for the three deaths that occurred as a result of asphyxia caused by smoke inhalation during the fire. Defendant was also convicted of second degree murder for the death of a firefighter that had a heart attack while fighting the fire. Defendant appealed his convictions and puts to issue the trial court’s denial of his motions for directed verdicts of acquittal.


Did the trial court properly deny defendant’s motion for directed verdicts of acquittal?




The court found that there was no error in the trial court's denial of defendant's motion for a directed verdict because the evidence was sufficient to send the indictments to the jury. The court concluded that commonwealth's experts had sufficient skill, knowledge, and experience in the investigation of arson to testify about the cause of the fire. The court could not say that the trial judge abused his discretion by admitting prior identification testimony. The court found no error in the denial of defendant's specific voir dire questions and jury instructions over all. However, the court held that the trial court erred in its instructions on proximate cause regarding the firefighter's death and reversed defendant's conviction on that murder count. The court affirmed defendant's other convictions.

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