Commonwealth v. WoodsAnnotate this Case
The Supreme Judicial Court affirmed the motion judge’s denial of Defendant’s motion seeking a new trial on the basis that he was the target of a grand jury investigation and that his grand jury testimony was improperly admitted under Commonwealth v. Woods, 466 Mass. 707 (2014) (Woods I), holding that the motion judge did not err.
In Woods I, the Supreme Judicial Court upheld the trial judge's finding that Defendant was not a target of the grand jury when he was called before the grand jury to testify. The Court further announced a prospective rule requiring that grand jury witnesses who are targets of a criminal investigation be given self-incrimination warnings before testifying. Following Woods I, Defendant filed a motion for a new trial arguing that new facts established that he was a target of a grand jury investigation. The motion judge concluded that Defendant was a target of the investigation but that the decision in Woods I upholding the admission of Defendant’s grand jury testimony did not depend on the factual finding that Defendant was not a target of the investigation. The Supreme Judicial Court affirmed the denial of Defendant’s motion for a new trial, holding that, irrespective of Defendant’s target status, he was not entitled to the new rule.