Commonwealth v. Rhoades case brief

Commonwealth v. Rhoades case brief summary
401 N.E.2d 342 (1980)

CASE SYNOPSIS

Defendant appealed the decision of the Superior Court of Suffolk County (Massachusetts), which convicted defendant of arson and four counts of murder in the second degree.

CASE FACTS
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.

DISCUSSION

• 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.

CONCLUSION
The court reversed defendant's conviction on one count of second degree murder and affirmed the other three murder convictions and the arson conviction.


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