Commonwealth v. Tyler
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The case involves Terrence Tyler, who was convicted of felony-murder in the first degree with the predicate felony of attempted unarmed robbery and assault with intent to rob. The incident occurred during a planned robbery of a marijuana dealer, Wilner Parisse, who was shot and killed during a physical altercation. Tyler appealed his conviction and filed two motions for a new trial. The first motion argued that his trial counsel was ineffective for not requesting an involuntary manslaughter jury instruction. The second motion requested the retroactive application of a court decision (Commonwealth v. Brown) that abolished felony-murder as an independent theory of liability for murder. Both motions were denied.
The Supreme Judicial Court of Massachusetts reviewed Tyler's case and his motions for a new trial. The court held that the rule in Brown was intended to apply prospectively, and there was no reason to depart from that limitation. The court also found that Tyler's trial counsel did not err by failing to request an involuntary manslaughter instruction, as the pre-Brown default rule applies here. The court further held that the trial judge's instruction did not allow the jury to find Tyler guilty of felony-murder for conduct only sufficient to convict him of manslaughter. The court declined to reduce the verdict of murder in the first degree to a lesser degree of guilt. Therefore, Tyler's conviction was affirmed, and the orders denying his motions for a new trial were also affirmed.
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