Commonwealth v. Harris (USA)


Lawrence Harris murdered his boyfriend in 2007 by hitting him over the head with a hammer and stabbing him 20 times in a bus terminal parking garage after his boyfriend broke up with him. He appealled his conviction, arguing that his confession to law enforcement was not voluntary. The Massachusetts Supreme Judicial Court disagreed and affirmed his conviction.  Harris claims to suffer from gender identity disorder.

Based on our review of the defendant’s interview with police,  we agree with the judge that the Commonwealth met its burden of proving, beyond a reasonable doubt, that the defendant’s statements were voluntary. Here, the defendant, although young in age, was an adult when questioned, cf. Commonwealth v. Ray, 467 Mass. 115, 133 (2014), went to the police station on his own volition, and was not restrained in any way while he was there. Commonwealth v. Cruz, 373 Mass. 676, 689 (1977). The Miranda warnings were administered at the beginning of the interview, and the defendant had no trouble understanding the instructions and questions of the officers. The defendant appeared sober, alert, oriented, and lucid.

The judge properly acknowledged that the defendant had no prior involvement with police and suffered from poor physical and mental health because of his anorexia, gender identity issues, difficulties resulting from his sexual orientation, and depression. The judge also fully took into account  the defendant’s “emotional fragility.” These factors are not necessarily outcome determinative. The weight of these factors, balanced against other factors considered by the judge, such as the fact that the defendant was able to work and was educated and intelligent, was for the judge to decide. See Commonwealth v. Walker, 466 Mass. 268, 274 (2013).

The  defendant’s grandmother testified that, because the defendant’s mother was in the military and traveled considerably, she raised the defendant for several years. At some point, the defendant moved to an apartment with his sister, but he maintained daily contact with his grandmother. According to the defendant’s grandmother,  the defendant had gender identity issues and carried a sculpting tool and hammer in his backpack because he had been “harassed.” She identified some of the defendant’s artwork in which he depicted himself as both a male and a female.

Following his arrest, the defendant was privately evaluated by Dr. DiCataldo. Based on his review of various reports, records, and information he gathered, as well as the police interview of the defendant and his own interviews with and testing of the defendant, Dr. DiCataldo testified that, at the time of the killing, the defendant suffered from a mental impairment, namely, borderline personality disorder.  In Dr. DiCataldo’s opinion, this mental impairment caused “a substantial impairment in [the defendant’s] behavior and his thought process” on the night of the killing. He explained that the impairment could have interfered with the defendant’s ability to form the requisite intent for murder and with the ability to make a calculated, premeditated decision to act.

Dr. DiCataldo explained that he based his opinion on the defendant’s fear, real or imagined, of abandonment; conflicted and stormy interpersonal relationships, characterized by quick infatuation; profound identity disturbance resulting from his gender identity issues; and problems with modulating and controlling anger. Dr. DiCataldo testified that the defendant’s mental impairment explained his “overreaction” to the victim’s decision to leave him.

Brockton man sentenced to life for murdering boyfriend – News – The Enterprise, Brockton, MA – Brockton, MA.

Brockton man’s hammer murder conviction upheld _ Boston Herald.

Commonwealth v. Harris.

Family of Brockton homicide victim did not know he was gay – Bay Windows.


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