SJC Declines to Extend ‘Adjutant’ Rule to Defense of Another
In Commonwealth v. Rateree (SJC-13599), the Massachusetts Supreme Judicial Court (SJC) addressed several key issues arising from an altercation involving the defendant, Shondell Q. Rateree, which led to multiple convictions, including assault with intent to maim, mayhem, and assault and battery by means of a dangerous weapon.
Background
On September 7, 2019, a confrontation occurred involving Rateree, a co-defendant, the victim, and a woman named Tyla Marceline. The sequence of events led to physical altercations and injuries among the parties involved. Rateree was subsequently convicted on multiple charges, including assault with intent to maim and mayhem.
Key Legal Issues and Court Findings
- Exclusion of ‘Adjutant’ Evidence Rateree contended that the trial judge improperly excluded evidence of the victim’s prior violent conduct, known as ‘Adjutant’ evidence, which could support his claims of self-defense and defense of another. The SJC upheld the trial judge’s decision, noting that there was no dispute regarding the victim initiating the altercation, making the ‘Adjutant’ evidence irrelevant to the self-defense claim. Furthermore, the court declined to extend the ‘Adjutant’ rule to encompass defense of another, citing potential complications and lack of precedent in other jurisdictions.
- Sufficiency of Evidence for Misleading a Police Officer The court found insufficient evidence to support Rateree’s conviction for misleading a police officer. The conviction was based on Rateree’s denial of being near the ocean on the night in question. The SJC determined that this simple denial, without additional evidence of intent to mislead, did not meet the statutory requirements for the offense.
- Duplicative Convictions Rateree argued that certain convictions were duplicative. The SJC agreed, vacating the convictions for assault with intent to maim and assault and battery by means of a dangerous weapon causing serious bodily injury, as they were lesser-included offenses of mayhem. Additionally, one count of assault and battery was vacated as duplicative of assault and battery by means of a dangerous weapon.
Conclusion
The SJC’s decision in Commonwealth v. Rateree clarifies the application of ‘Adjutant’ evidence, particularly its inapplicability to defense of another, and addresses issues related to evidentiary sufficiency and duplicative convictions. The case has been remanded to the Superior Court for resentencing on the remaining convictions.
