In Com. v. Pring-Wilson, the Supreme Judicial Court ruled today that Alexander Pring-Wilson, previously convicted of voluntary manslaughter after an altercation in Cambridge, is entitled to a new trial.
In 2005, after Pring-Wilson's conviction, the SJC decided the case of Com. v. Adjutant, 443 Mass. 649. In that case, much as in Pring-Wilson's, the defense had sought to introduce evidence of prior bad acts by the victim to support the notion that the defendant had acted in self-defense. The court in Adjutant established a new rule "that 'where the identity of the first aggressor is in dispute and the victim has a history of violence,' the judge has the discretion to admit 'evidence of specific acts of prior violent conduct that the victim is reasonably alleged to have initiated, to support the defendant's claim of self-defense.' Declaring that the decision marked a 'new common-law rule of evidence,' we stated that the rule 'shall apply only prospectively.'"
Shortly after that decision, and after holding a hearing, the trial judge concluded, "in the exercise of her broad discretion under rule 25 (b) (2), that the integrity of the defendant's trial was compromised by his inability to introduce evidence of the violent pasts of Colono and Rodriguez." The Commonwealth appealed, and direct appellate review was granted. In today's case, the SJC affirmed the trial judge's order granting the defendant a new trial.
The opinion describes the facts of the case at some length, and also provides an analysis of judicial discretion to grant a new trial.
