Petition for Writ of Certiorari — Lavar Eady, Petitioner v. Massachusetts

Supreme Court briefSep 6, 2019

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No. __________

In The

Supreme Court Of The United States

____________________________________________

LAVAR EADY,

Petitioner,

COMMONWEALTH OF MASSACHUSETTS

Respondent.

____________________________________________

On Petition For Writ Of Certiorari

To The Appeals Court Of Massachusetts

____________________________________________

APPENDIX

____________________________________________

Brad P. Bennion

Counsel of Record

P.O. Box 890118

East Weymouth, Massachusetts 02189

(617) 943-6164

bradpbennion@gmail.com

September 6, 2019

App. 1

Table Of Contents

Commonwealth v. Lavar Eady,

95 Mass. App. Ct. 1116, 125 N.E.3d 802 (2019) ........................A-3

Commonwealth v. Lavar Eady,

482 Mass. 1107 (2019) ................................................................A-5

Transcript of 6/8/2017 (Vol. 3) pp. 31-47

Ms. Tyson’s Testimony ...............................................................A-6

App. 2

Commonwealth v. Eady, 95 Mass.App.Ct. 1116 (2019)

125 N.E.3d 802

95 Mass.App.Ct. 1116

Unpublished Disposition

NOTICE: THIS IS AN UNPUBLISHED OPINION.

NOTICE: Summary decisions issued by the Appeals

Court pursuant to its rule 1:28, as amended by

73 Mass. App. Ct. 1001 (2009), are primarily

directed to the parties and, therefore, may not

fully address the facts of the case or the panel's

decisional rationale. Moreover, such decisions are

not circulated to the entire court and, therefore,

represent only the views of the panel that decided

the case. A summary decision pursuant to rule 1:28

issued after February 25, 2008, may be cited for

its persuasive value but, because of the limitations

noted above, not as binding precedent. See Chace

v. Curran, 71 Mass. App. Ct. 258, 260 n.4 (2008).

Appeals Court of Massachusetts.

COMMONWEALTH

Lavar EADY.

18-P-907

Entered: May 31, 2019.

By the Court (Wolohojian, Kinder & Hand, JJ. 2 )

MEMORANDUM AND ORDER

PURSUANT TO RULE 1:28

*1 The defendant raises three arguments in this direct

appeal from his conviction, after a jury trial, of distributing

a class B substance (fentanyl), as a subsequent offense, in

violation of G. L. c. 94C, § 32A (b). First, he asks us

to conclude that the testimony of the substitute chemist in

this case violated his right to confront witnesses under the

Sixth Amendment to the United States Constitution, in effect

asking us to overrule the Supreme Judicial Court's decision

in Commonwealth v. Grady, 474 Mass. 715 (2016). Second,

the defendant argues that the Commonwealth's evidence of

distribution was insufficient because a reasonable jury could

not find, beyond a reasonable doubt, that he had acted as the

seller rather than the buyer of the drugs at issue. Third, he

contends that a substantial risk of a miscarriage of justice

occurs whenever a Tuey-Rodriquez charge is given, and that it

did so here because the instruction was delivered prematurely.

See Commonwealth v. Rodriquez, 364 Mass. 87, 101-102

(1973). We affirm.

As to the defendant's first argument, although we respect

defense counsel's zealous advocacy on behalf of his client

in seeking to change the law, this court lacks the power to

overrule the Supreme Judicial Court. See Commonwealth v.

Dube, 59 Mass. App. Ct. 476, 485 (2003); Commonwealth

v. Healy, 26 Mass. App. Ct. 990, 991 (1988). As a result,

the defendant's first argument is controlled -- and defeated -by Commonwealth v. Grady, 474 Mass. 715. The substitute

chemist's testimony concerning the composition of the

narcotic substance was permissible as her own opinion based

on her review of data generated by a nontestifying analyst.

Id. at 723-724. 1 See Commonwealth v. Greineder, 464 Mass.

580, 584 (2013).

As to the defendant's second argument, we review the

sufficiency of the evidence under the familiar framework

of Commonwealth v. Latimore, 378 Mass. 671, 677-678

(1979), taking the evidence (and the reasonable inferences

to be drawn from it) in the light most favorable to the

Commonwealth, to determine whether there was enough

evidence to permit a rational trier of fact to find beyond a

reasonable doubt that the defendant distributed the drugs.

Commonwealth v. Johnson, 481 Mass. 710, 728-729 (2019).

Contrary to the defendant's assertion, the Commonwealth's

evidence did not make it just as likely that the defendant was

simply a user seeking to purchase drugs. See Commonwealth

v. Russell, 46 Mass. App. Ct. 307, 311 (1999), citing

Commonwealth v. Latney, 44 Mass. App. Ct. 423, 425-426

(1998). Police observed the defendant interact in two separate

instances with individuals in a manner consistent with an

exchange of drugs; the encounters were brief and appeared

transactional; there were no indications that the encounters

were social. As to the first encounter, the defendant briefly

met with a couple and their arms went back and forth

towards each other. The couple were then observed smoking

a substance with a glass pipe. Within an hour, the defendant

had a second encounter; this time, he met with a woman

who appeared to have nothing in her hands beforehand, but

afterwards had an item in her hand which she inspected

before placing in her mouth. Again, the encounter was brief

and did not appear social; the woman's and defendant's

arms moved back and forth towards each other briefly. The

woman then met a man, and the two went together to a

nearby sheltered area. Police recovered from the man a

small plastic bag containing fentanyl which he had placed in

his mouth. When the defendant was immediately thereafter

original3U.S. Government Works.

Commonwealth v. Eady, 95 Mass.App.Ct. 1116 (2019)

125 N.E.3d 802

apprehended, he had no drugs or drug paraphernalia, but

did possess a cell phone and $ 717. The defendant was

sweating so heavily that his sweat formed a puddle on

the ground where he was standing. See Commonwealth v.

Sinforoso, 434 Mass. 320, 328 (2001) (viewing evidence in

light most favorable to Commonwealth, defendant's sweating

may support consciousness of guilt).

*2 Finally, we are not persuaded by the defendant's

argument that a substantial risk of a miscarriage of justice

occurred from the timing of the Tuey-Rodriquez charge. This

court reviews both the decision to give a Tuey-Rodriquez

charge and its timing for an abuse of discretion. See

Commonwealth v. O'Brien, 65 Mass. App. Ct. 291, 295

(2005). Here, although the defendant asserts that the charge

was prematurely given, the record does not support his claim.

The case was submitted to the jury on the second day of this

short trial. After deliberating approximately two and one-half

hours, the jury asked a question about what would happen

“since we can't agree.” The judge dismissed the jurors for the

day. The following day, the judge found that the jurors had not

yet completed “due and thorough deliberation,” G. L. c. 234A,

§ 68C, and instructed them to continue their deliberations.

Several hours later, the jurors submitted a note stating that

they remained unable to reach a unanimous decision and

did not feel that more time would help “sway either party.”

The judge found that the jury had deliberated for six or

seven hours by this time -- approximately as long as the

testimony had taken. At this point, both the prosecutor and

defense counsel told the judge that it would be appropriate to

deliver the Tuey-Rodriquez instruction. We discern no abuse

of discretion in these circumstances.

Nor are we persuaded by the defendant's argument that the

charge is coercive in all instances, let alone that it was so here

where the judge's “comments [we]re balanced and not slanted

toward conviction.” Commonwealth v. Abdul-Alim, 91 Mass.

App. Ct. 165, 173 (2017).

Judgment affirmed.

All Citations

95 Mass.App.Ct. 1116, 125 N.E.3d 802 (Table), 2019 WL

2321886

Footnotes

The panelists are listed in order of seniority.

The Commonwealth concedes, and we agree, that the substitute chemist's direct examination testimony with respect to

the weight of the substance was erroneously elicited and admitted. However, it was not objected to and the defendant

has not shown or argued any substantial risk of a miscarriage of justice resulting from its admission. We note that the

weight of the substance was neither required to be proved nor otherwise at issue.

End of Document

original4U.S. Government Works.

Commonwealth v. Eady, Slip Copy (2019)

2019 WL 3713804 (Table)

July 31, 2019

2019 WL 3713804 (Table)

Only the Westlaw citation is currently available.

(This disposition is referenced

in the North Eastern Reporter.)

Supreme Judicial Court of Massachusetts.

COMMONWEALTH

Lavar EADY

End of Document

Reported below: 95 Mass. App. Ct. 1116 (2019).

Opinion

*1 Appellate review denied.

All Citations

Slip Copy, 2019 WL 3713804 (Table)

original5U.S. Government Works.

VOLUME: III

PAGES: 4-111

EXHIBITS: 13-14

COMMONWEALTH OF MASSACHUSETTS

Suffolk, SS

Superior Court

Criminal Action

No. 2015-11024

* * * * * * * * * * * * * * * * * * *

COMMONWEALTH OF MASSACHUSETTS

LAVAR EADY

* * * * * * * * * * * * * * * * * * *

JURY TRIAL

BEFORE: WILKINS, J.

JUNE 8, 2017

APPEARANCES:

ON BEHALF OF THE COMMONWEALTH:

Suffolk County District Attorney’s Office

BY: KAUSHAL RANA, A.D.A.

ON BEHALF OF THE DEFENDANT:

BY: WILLIAM ROA, ESQ.

Boston, Massachusetts

Courtroom 806

Christine Doran Kerrigan

Official Court Reporter

App. 6

Page 2 of 112

INDEX

Direct

Cross

Redirect

Recross

WITNESS:

Adrian Pinto

(by Mr. Rana)

(by Mr. Roa)

Christine Tyson

(by Mr. Rana)

(by Mr. Roa)

Robert England

(by Mr. Rana)

(by Mr. Roa)

PAGE

Jury Charge

Closing arguments

(by the Defendant)

(by the Commonwealth)

Jury Charge

EXHIBITS:

PAGE

FOR IDENTIFICATION:

Jury Question

App. 7

Page 3 of 112

INDEX

EXHIBITS:

PAGE

IN EVIDENCE:

Plastic Bag Containing Drugs

Brown Envelope

App. 8

Page 31 of 112

Oh, one last thing.

Did you -- you can still bring them

down.

Did you decide whether you want me to pick the foreperson

or whether you're content to have them pick their foreperson?

Again, you don't have to decide right now.

MR. ROA:

Yeah, sure, I'll be able to give you a response.

THE COURT:

(Court in recess.)

Okay. Great. Okay.

(Court in session.)

(Defendant is present with counsel.)

(Jury in.)

THE COURT:

witness, please.

All right. Welcome back.

MR. RANA:

Ms. Christine Tyson.

THE COURT:

Good morning.

THE WITNESS:

THE COURT:

Mr. Rana, your next

Good morning.

Mr. Rana.

CHRISTINE TYSON, sworn

DIRECT EXAMINATION

BY MR. RANA:

the record.

Good morning, ma'am.

Could you please state your name for

App. 9

Page 32 of 112

Christine Tyson, T-Y-S-O-N.

And where do you work?

The Massachusetts State Police Crime Lab.

How long have you worked there?

I have worked there since April of 2013.

What are your job duties there?

I'm a forensic scientist three which is a supervisor within

the drug identification unit.

Can you describe your educational background?

I have a bachelor of science degree in biochemistry from

Temple University.

And what was your major -- I'm sorry. You said chemistry?

Biochemistry.

Biochemistry. How many cases have you analyzed to date

ballpark?

I've analyzed thousands of cases.

Now, prior to being in your supervisory role, what was your

previous position there?

September of 2013.

Police Department as a forensic scientist in the drug

identification unit from 2007 until 2013.

the duties you had as a forensic scientist one?

I was a forensic scientist one from April of 2013 until

Prior to that I worked for the Philadelphia

When you say a forensic scientist one, what were some of

App. 10

Page 33 of 112

You're training in the protocols of the crime laboratory.

And now you said you were a forensic scientist three, is

that correct?

Yes, that's correct.

And in that role, do you review your colleague's reports?

Yes, I do.

How often do you review them?

I review them daily.

Can you describe the process about how you review them?

Each report there's data generated.

form of charts and graphs, and there's notes that are associated

with the evidence when they open it and analyze it.

those notes are reviewed, the data is reviewed to ensure that

the conclusions reached on the final report are supported by all

the data in the documentation in the case file.

The state police lab that you work at, is it accredited?

Yes, it is.

Can you describe, if you know, how the accreditation

process works how it gets accredited?

accreditation process.

ASCLAD, the American Society or Crime Laboratory Directors

Laboratory Accreditation Board.

that comes out and checks our protocols and procedures and

Sure. We have an external agency.

The data is in the

All of

It's a voluntary

The agency that we are accredited by is

App. 11

They are an independent agency

Page 34 of 112

everything, the management structure to the ISO17025

international standards.

met by testing facilities that want to be accredited.

lab also puts additional requirements on forensic laboratories.

At the end of the audit process, we receive the accreditation

documentation.

drug cases?

Approximately 40 times.

Do you know some of the courts that you've testified in?

In the Commonwealth of Massachusetts I've testified in

municipal and superior courts, and the municipal courts of

Philadelphia and the United States Federal Court.

receives substances from police agencies to test?

facility in Horse Pond Road in Sudbury.

evidence in a sealed condition.

technicians.

identification number and a barcode.

throughout the facility.

evidence storage vault until it's asked for analysis.

vault?

These are standards that need to be

ASCLAD

How many times have you testified as a chemist expert in

Now, can you explain in general how you and your lab

Police agencies throughout the Commonwealth come to our

They bring their

It's received by our evidence

At that point it receives a unique laboratory

That's how we track it

The evidence is then logged into our

So until the substance is analyzed, it stays in a locked

App. 12

Page 35 of 112

That's correct.

And how -- if you can how are assignments given to specific

chemists or analysts?

Assignments are handed out by the supervisors.

Now when a substance comes in to be tested, you said that

it's given a unique lab number?

Yes, that's correct.

I want to draw your attention to lab number 15–18291.

you do the initial testing on this substance or this item?

No, I did not.

Who did?

Heather Moett(ph).

And is she currently still at the lab?

No, she's not.

Now, generally when a chemist leaves the state police, can

you describe kind of what happens to the items they've already

tested?

All of the evidence still has the reports associated with

it.

The evidence after it's been tested is returned to the

submitting agency.

that had the evidence to begin with.

the reports are all maintained in our facility.

then -- I'm sorry. The reports are available for review by a

substitute chemist should testimony be required.

Did

So the evidence itself is with the agency

App. 13

We keep the reports and

The evidence is

Page 36 of 112

So when a substitute chemist is assigned, can you describe

kind of what the substitute chemist generally does?

documents associated with the analysis, and at that point they

determine, based on the documents available, what the substance

contains.

at the -- you said the notes and the documents and the data and

forms an independent opinion?

Yes, that's correct.

Okay. Now, the equipment that's used during the testing of

these substances, can you kind of explain how it's determined

whether or not the equipment is functioning properly?

pieces of the equipment that we use is part of the quality

control program.

that's used depends on what types of quality procedures are

performed.

depending on the instrument.

within the laboratory.

So the equipment is checked essentially on a regular basis?

Yes.

Okay. Now, I want to draw your attention specifically to

lab number 1518291.

The substitute chemist performs a review of all of the

So what you are saying is that a substitute chemist looks

Sure.

We have quality control procedures.

Each of the

Depending on the instrument or the balance

They are performed weekly, monthly, or daily

It's all documented and recorded

Was there a substitute chemist that was

App. 14

Page 37 of 112

assigned for this matter?

Yes.

And that's you?

That's correct.

Do you know or when looking at when you were assigned this

matter do you know the name or names that were associated with

this lab number?

The suspects?

Yes, or the individuals, yes.

I have it listed on the SP295.

top of my head.

Is your memory exhausted as to the names?

Yes.

I couldn't state it off the

MR. RANA:

Your Honor, may she refer to her notes?

THE COURT:

Yes.

Okay.

And is your memory refreshed now?

Yes.

And what were the names associated with this lab number?

We have three on here: Lavar Eady, Craig Smith, and Shannon

Barao, B-A-R-A-O.

this lab number?

Thank you.

How many item numbers or items were tested on

There was one.

App. 15

Page 38 of 112

And what was the description provided, if you have it, of

what the item was?

It was a plastic bag of tan powder.

Now, can you explain what the procedure is for analyzing a

powder?

So the powder is weighed without the packaging to determine the

net weight of the powder.

the situation of a powder, we perform ultraviolet visible

spectroscopy test.

be present in the powder, it gives us the guidance for the

further analysis that we would perform.

would perform either a FTIR Fourier transform infrared

spectroscopy or a gas chromatography/mass spectrometry or a

GCMS.

mentioned, were you able to review the data and the notes with

regards to that test for this powder?

Yes, I was.

And what's your opinion as to what the data indicated?

That data indicates it's consistent with acetaminophen.

And explain what acetaminophen is.

Acetaminophen is the active ingredient in Tylenol.

Now, what is FTIR?

Sure, all evidence is weighed prior to analysis beginning.

The evidence is then screened.

This gives us a general idea of what should

Based on that test, we

Now, with regards to the UV spectroscopy that you just

App. 16

Page 39 of 112

Fourier Transform infrared spectroscopy.

It's an

instrument that uses infrared light to give a spectrum of the

compound of interest.

And was that test done for this item or lab number?

No, it was not.

And you mentioned GCMS.

Yes.

Was that test done for this item number?

Yes, it was.

And were you able to review the data that was generated as

a result of that test?

Yes.

And what's your opinion with regards to that data regarding

this substance?

The substance in the test for GCMS contains fentanyl.

You said fentanyl?

Yes, fentanyl.

And you said that the items are generally weighed. Was this

item weighed?

Yes.

What was the weight of the tested powder?

Zero point zero nine grams.

I'm sorry.

MR. RANA:

May I approach, Your Honor?

THE COURT:

Yes.

App. 17

Page 40 of 112

to take a look at this, and see if you recognize any numbers,

markings, or anything like that?

Sure.

So what do you recognize?

So this is very consistent with the packaging that leaves

our laboratory.

the barcode that is how the evidence is tracked throughout the

laboratory.

sticker is placed by the submitted agency when they submit the

evidence.

initials and the date that she analyzed the evidence along with

the laboratory number is inside the packaging on the item

analyzed itself and inside of the seal.

to this particular case, is that lab number on that package

there?

inside of here on this barcode sticker.

analyst on this side of the evidence and on this side of the

evidence.

how evidence is repackaged after we test it.

Ms. Tyson, I'm going to hand you a plastic bag.

I want you

This is the evidence sticker that's put on with

The laboratory number is also inside here.

That

Additionally, the original analyst, Heather, her

Is there -- you mentioned there was a lab number assigned

Yes, it's the lab number is here - 1518291.

It's also

It's handwritten by the

It's also handwritten on the packet itself which is

Thank you.

MR. RANA:

Your Honor, I would like to have what has been

App. 18

Page 41 of 112

marked for identification as Exhibit A be marked as an exhibit.

MR. ROA:

No objection.

I'll ask you one more question --

THE COURT:

What's the number on that one?

THE COURT REPORTER:

THE COURT:

(Whereupon Exhibit No. 13, Plastic Bag Containing Drugs

(formerly A for identification) was marked as an exhibit.)

Exhibit 13.

Thank you.

Exhibit 13, I'm just going to hand it to you again real

quick.

been marked it says one plastic bag tan powder heroin.

generated by the police agency or by the lab?

This sticker is by the police agency.

Okay. So where it says tan plastic bag of heroin, that was

not generated by the lab, that was generated by the police

agency, is that right?

it in this exterior one.

agencies, they kind of -- well, is it common what they may have

written initially on a bag it turns out testing makes it a

different substance?

Yes.

So they don't -- you're the one that does the testing, is

If you noticed in this this exhibit there is what has

Correct. This bag is what's submitted by the lab.

Was that

We put

And, Ms. Tyson, when you receive items from police

App. 19

Page 42 of 112

that right?

Yes, that's correct.

MR. RANA:

May I have one moment, Your Honor?

THE COURT:

Okay.

MR. RANA:

Your Honor, I would just ask also that what's

been marked premarked as an exhibit, Exhibit B for

identification I ask that this also be marked as an exhibit now.

THE COURT:

MR. ROA:

THE COURT:

All right. So Exhibit B will be in evidence

MR. RANA:

I have nothing further, Your Honor.

THE COURT:

Okay. Cross-examination.

MR. ROA:

(Whereupon Exhibit No. 14, Brown Envelope (formerly B for

identification) was marked as an exhibit.)

Any objection?

What is B, just the bag?

No objection.

now.

Yes.

CROSS-EXAMINATION

BY MR. ROA:

Good morning, Ms. Tyson.

Good morning.

You indicated that you have a bachelor's degree?

Yes, that's correct.

You do not have a master's degree, correct?

Correct.

App. 20

Page 43 of 112

You do not have a PhD?

Correct.

You are not in the process of obtaining those things?

No, I am not.

In college, you did not take any courses in fentanyl?

No.

You did not take any courses in how to work any of this

machinery that you were discussing with Attorney Rana?

the instrumentation that we use on a daily basis.

you've always worked for the government in one capacity or

another?

Yes.

It's fair to say that you've never testified for the

defense in a criminal case?

I've not had the opportunity, no.

You indicated that -- strike that. You were just shown an

evidence bag?

Yes.

That's the first time you've seen that bag, correct?

To my knowledge, yes.

So, again, prior to today you had not seen that bag?

Not that I can remember, no.

I did have an instrumentation course which goes over all

It's fair to say that other than for a brief period of time

App. 21

Page 44 of 112

You personally did not test the contents of that bag?

That's correct.

Your colleague did or former colleague?

Yes, that's correct.

Attorney Rana showed you I believe exhibit -- the

certificate of analysis that you were referring to earlier?

He did not show me the certificate.

MR. ROA:

THE COURT:

May I approach?

Yes.

Ms. Tyson, do you know when that bag that you were

referring to when it first into the lab?

I refer to the notes?

Is your memory exhausted?

Yes.

It was received on 7/28/2015.

And you described the procedure that was followed within

the lab?

Yes.

So once it's received by your drug lab, it goes into a

vault?

Yes.

That's a locked vault?

Yes, that's correct.

App. 22

Page 45 of 112

And who has access to that vault?

The laboratory director, the deputy director of forensic

chemistry, the manager of forensic chemistry, all of the drug

chemists, and the evidence personnel.

get into that vault?

Yeah, it's a card access.

I see. And I take it in that vault there's a numbers of

items of evidence from various cases?

Yes, that's correct.

Isn't it true that whenever someone's obtaining a piece of

evidence that he or she would have to sign out for that that

piece of evidence out?

Yes, that's the scanning through the electronic system.

I see.

chemist to verify that, or the chemist can go in on their own?

There are two people required to open the vault door.

But you don't know if that procedure was followed in this

case?

door so it has to be followed in order to get the evidence out

of the vault.

knowledge of that actually happening, though?

So all the drug chemists have a key or the combination to

Our badges allow us in.

And do you know if anyone has to go in with the

In order to obtain the evidence, two people must open the

I guess my question, you personally did -- you have no

App. 23

Page 46 of 112

No, I didn't personally observe it happening.

And you personally haven't seen any documentation that

would verify that two people actually went into the vault to

obtain that piece of evidence that you were looking at?

Correct.

Do you know when this -- strike that. This -- the item of

evidence that you were looking at earlier, that was tested on

August I believe 11th of 2015?

I believe that's when the certificate was authored.

Do you know when the substance was tested then?

If I may refer to the notes.

Is your memory exhausted?

Yes.

August 10, 2015 was when it was tested.

And, again, by the same procedure you're describing either

that day or the day before the previous chemist would have had

to have gone into the vault, correct?

Yes.

And after this analysis is done, is that some procedure

followed, two people have to bring it into the vault?

bin is then taken by our evidence technicians and placed into

the vault pending review of the case.

So the evidence is placed in a pending review bin.

App. 24

That

Page 47 of 112

Pending review by a supervisor?

A supervisor, yes.

And when you say bin, describe that.

It is a locked bin on both sides with a slot where the

evidence goes into, and the evidence personnel has keys to

unlock the bin to get the evidence out of it, and then it's

placed in the vault until the evidence is reviewed and once --

I'm sorry -- the data is reviewed.

the evidence then goes to a different vault where it's ready for

return to the submitting agency.

actually tested the substance that was in the bag that you were

looking at earlier?

Once the data is reviewed,

And, again, just to confirm, you personally have not

That's correct.

MR. ROA:

I have no further questions.

THE COURT:

Redirect?

MR. RANA:

Nothing further.

THE COURT:

Thank you.

MR. RANA:

Sidebar, Your Honor.

THE COURT:

Okay.

(Sidebar commences:

MR. RANA:

You're excused.

You may step down.

Your Honor, Officer England is not able to be

here.

He apparently executed a search warrant last night so

he's in West Roxbury Court.

I apologize to the Court.

App. 25

I told

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