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May 26, 2014

Erroneous Jury Instruction Leads to Reversal of Defendant's First Degree Murder Conviction

Last week, the Massachusetts Supreme Judicial Court (SJC) reversed the conviction of a criminal defendant for first degree murder after finding that the trial judge had erred in instructing the jury as to their deliberations on first degree murder versus the lesser offense of second degree murder.

In Commonwealth v. Figueroa, the defendant did not deny that he shot and killed the victim. Instead, the issue was whether the defendant's killing was done with the intent to kill or deliberate premeditation. If the jury believed that the defendant had the requisite intent, then a verdict of first degree murder would have been appropriate. However, if the jury believed that the defendant was so intoxicated from alcohol and/or cocaine that he could not have formed the legal intent, then a conviction of second degree murder would have been appropriate.

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