Commonwealth v. CombsAnnotate this Case
The Supreme Judicial Court reversed Defendant’s convictions for murder in the first degree, kidnapping, armed robbery, and assault by means of a dangerous weapon, holding that the location of the crimes - whether they occurred in Massachusetts or Connecticut, where the victim’s body was found - remained too speculative to sustain the jury’s finding of guilt beyond a reasonable doubt.
During trial and as part of his motion for a required finding of not guilty, Defendant argued that there was insufficient evidence to prove beyond a reasonable doubt that the victim was killed in Massachusetts. The trial judge denied the motion but submitted the question of territorial jurisdiction to the jury. On appeal, the Supreme Judicial Court held that a rational trier of fact could not have found beyond a reasonable doubt that the victim was killed in Massachusetts, as opposed to in Connecticut, and therefore, there was insufficient evidence for a finding beyond a reasonable doubt of territorial jurisdiction.