Commonwealth v. Watson
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The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree and vacated his conviction of accessory after the fact to murder, holding that, under the circumstances, Defendant could not convicted of joint venture murder in the first degree and of accessory after the fact.
Specifically, the Supreme Judicial Court held (1) there was sufficient evidence to prove murder in the first degree; (2) the jury instruction on joint venture liability was a correct statement of the law; (3) while the evidence was sufficient to convict Defendant as an accessory after the fact, because one cannot properly be convicted of a crime and of being an accessory after the fact to the same crime, this conviction must be vacated; (4) the trial judge did not abuse her discretion by failing to order the trial severed; (5) reversible error did not result from the judge's response to a jury question; and (6) there was no reason for the Court to exercise its authority under Mass. Gen. Laws ch. 278, 33E.
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