investigators | business fraud | criminal defenseMichael O'Laughlin
Court of Appeals Reverses Conviction of client Michael O'Laughlin
Jun.11.2009
In a rare decision upholding a lower court decision overturning a jury verdict, the 1st Circuit Court of Appeals overturned the Massachusetts Supreme Judicial Court [SJC] in the murder case of client Michael O'Laughlin. Citing the "the extremely high bar " in such instances, the court found in part: "Taken together, the circumstantial evidence in this case, even when drawing all reasonable inferences in favor of the prosecution, does not permit any rational jury to conclude that O'Laughlin was the assailant beyond a reasonable doubt." The opinion is notable for its thorough parsing--and ultimate rejection-- of the consciousness of guilt evidence cited by the SJC.
The court summed up the case as follows:
"A Massachusetts Superior Court jury had convicted O'Laughlin of the following counts: (1) burglary and armed assault in a dwelling; (2) armed assault in a dwelling; (3) armed assault with intent to murder; and(4) assault and battery by means of a dangerous weapon. The Superior Court then sentenced O'Laughlin to 35-50 years on Counts One and Two; 19-20 years on Count 3; and 9-10 years on Count 4, ruling that the sentences were to be served concurrently.
The intermediate Massachusetts Appeals Court reversed the judgments holding that there was insufficient evidence to support the verdicts. Commonwealth v. O'Laughlin, 830 N.E.2d 222 (Mass. App. Ct. 2005) (hereinafter "O'Laughlin I"). The Massachusetts Supreme Judicial Court ("SJC") reinstated the judgment reasoning that there was sufficient evidence to support the verdicts. Commonwealth v. O'Laughlin, 843 N.E.2d 617 (Mass. 2006) (hereinafter "O'Laughlin II").
O'Laughlin filed a petition for a writ of habeas corpus in the United States District Court for the District of Massachusetts on grounds that (1) the SJC's (which had ruled that was objectively unreasonable because there was insufficient evidence to support a guilty verdict and (2) that the SJC violated his constitutional right to present a defense. The district court denied O'Laughlin's petition for habeas relief.
After careful consideration, we reverse the judgment of the district court and order the district court to grant the petition. "
A full factual recounting of the case is found here. Michael remains in prison pending a state appeal for an en banc hearing by a full panel of 1st Circuit judges.
The court summed up the case as follows:
"A Massachusetts Superior Court jury had convicted O'Laughlin of the following counts: (1) burglary and armed assault in a dwelling; (2) armed assault in a dwelling; (3) armed assault with intent to murder; and(4) assault and battery by means of a dangerous weapon. The Superior Court then sentenced O'Laughlin to 35-50 years on Counts One and Two; 19-20 years on Count 3; and 9-10 years on Count 4, ruling that the sentences were to be served concurrently.
The intermediate Massachusetts Appeals Court reversed the judgments holding that there was insufficient evidence to support the verdicts. Commonwealth v. O'Laughlin, 830 N.E.2d 222 (Mass. App. Ct. 2005) (hereinafter "O'Laughlin I"). The Massachusetts Supreme Judicial Court ("SJC") reinstated the judgment reasoning that there was sufficient evidence to support the verdicts. Commonwealth v. O'Laughlin, 843 N.E.2d 617 (Mass. 2006) (hereinafter "O'Laughlin II").
O'Laughlin filed a petition for a writ of habeas corpus in the United States District Court for the District of Massachusetts on grounds that (1) the SJC's (which had ruled that was objectively unreasonable because there was insufficient evidence to support a guilty verdict and (2) that the SJC violated his constitutional right to present a defense. The district court denied O'Laughlin's petition for habeas relief.
After careful consideration, we reverse the judgment of the district court and order the district court to grant the petition. "
A full factual recounting of the case is found here. Michael remains in prison pending a state appeal for an en banc hearing by a full panel of 1st Circuit judges.