Commonwealth v. Coleman

Brief Fact Summary.

Two men outside a nightclub attacked Defendant. Defendant went to a nearby car and retrieved a gun. Defendant went by to the area where the fight was occurring and shot the victim in the chest. Defendant was convicted of first-degree murder with deliberate premeditation and the unlawful possession of a firearm. Defendant appealed the murder conviction.

Synopsis of Rule of Law.

Pursuant to Massachusetts’s law, a defendant must have a cool reflection of his or her decision to kill to constitute premeditation.

Facts.

Two men attacked Wayland Coleman, Defendant, outside of a nightclub. The fight expanded, and several people joined and threw punches. Defendant escaped from the crowd and went to a car nearby and retrieved a gun from the trunk. Defendant went back to where the fight was taking place. The evidence presented indicates that the victim followed Defendant to the car. Subsequently, Defendant shot the victim in the chest. There is evidence that indicates that Defendant shot the victim twice after the victim fell to the ground. Defendant then fled the scene with three other men in a car. The victim died from injuries, and Defendant was convicted of first-degree murder with deliberate premeditation and the unlawful possession of a firearm. Defendant motioned for the trial court to reduce the murder conviction to a manslaughter conviction. The trial court denied the motion and the later request for reconsideration. Defendant appealed the first-degree murder conviction alleging the Prosecution failed to assert sufficient evidence to support deliberate premeditation.

Issue.

Whether, pursuant to Massachusetts’s law, a defendant must have a cool reflection of his or her decision to kill to constitute premeditation.

Held.

Yes, pursuant to Massachusetts’s law, a defendant must have a cool reflection of his or her decision to kill to constitute premeditation.

Discussion.

First-degree murder conviction requires a finding that the defendant: (1) the unlawfully killed the victim (2) with both deliberate premeditation and malice aforethought. Pursuant to Massachusetts’s law, a defendant must have a cool reflection of his or her decision to kill to constitute premeditation. This act of coolly reflecting on the matter may occur within a matter of seconds. Here, Defendant contends that a finding of deliberate premeditation is not present because Defendant was suddenly attacked outside the nightclub. Also, the incidents that preceded the fight occurred unexpectedly. Also, even though the victim followed Defendant to the car, the record is silent as to whether the victim was unarmed or trying to attack Defendant physically. Thus, a reasonable jury could conclude that Defendant deliberately premeditated when he walked to the vehicle and made the decision to kill as he retrieved the gun. Under state law, a judge has the discretion to reduce a jury’s verdict if it is in the interests of justice. Nevertheless, a judge’s discretion to do such a thing must be used carefully. Defendant’s contention that the trial judge should have reduced his sentence is improper because the evidence does not indicate that the victim’s death was a result of a sudden fight or provocation. Therefore, the jury properly found that there was sufficient evidence to convict Defendant of first-degree murder, and the verdict is affirmed.