Commonwealth v. Watkins (No. 1)Annotate this Case
The Supreme Judicial Court reversed the decision of the superior court granting a new trial in this criminal case after concluding that the evidence was insufficient to support Defendant's murder conviction on a theory of joint venture felony-murder, holding that granting Defendant's motion for a new trial was error.
Defendant was convicted of murder in the first degree, armed robbery, and kidnapping. The court of appeals affirmed. More than forty years later, Defendant filed a motion for a new trial on the murder indictment, arguing that the Commonwealth presented insufficient evidence for the felony-murder conviction. The superior court judge granted the motion. The Supreme Judicial Court reversed, holding (1) the motion judge had authority to consider the sufficiency of the evidence following the Supreme Judicial Court's 33E plenary review on direct appeal; but (2) Defendant was estopped from raising the claim that the evidence was insufficient for the jury to have found that Defendant was a joint venturer in the armed robbery.