Case Study on "Analysis of Procedural Law"

Case Study 4 pages (1321 words) Sources: 4 Style: MLA

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Case study of the Louise Woodward Trial

In the case of the Commonwealth v. Louise Woodward 427 Mass. 659; 694 N.E.2d 1277; 1998 Mass, the Commonwealth of Massachusetts tried Louise Woodward for the death of eight-month-old Matthew Eappen. The eight-month-old infant died after a severe head injury. The infant was in the lone care of defendant who worked as au pair for the family. Following a trial, a jury found Louise Woodward guilty of second degree murder and sentenced her to life in prison. The trial court reduced the verdict to involuntary manslaughter and vacated the sentence. The prosecution argued that the trial court abused its discretion in reducing the jury's verdict and erred in refusing to issue a jury instruction on the lesser included offense of manslaughter. The court decided that the trial court should have included the lesser included offense upon the request of the prosecution, despite defendant's objection, because the evidence permitted them to do so. The jury's verdict of second degree murder rendered the error harmless. The court held that Rule 25 authorized the trial court to enter a finding of guilty of any included offense upon a motion for a directed verdict and thus, there was no error in the reduction of the verdict. The court also said that the trial court was responsible for sentencing and the court had no authority to review an otherwise lawful sentence. It found the sentence to be within the statutory limits (Commonwealth v. Woodward, 1998).

The Commonwealth offered evidence that the cause of Matthew's death was severe head trauma inflicted on February 4, 1997, while he was in the custody of Woodward. The Commonwealth wanted the jury to be provided with instructions on murder in the first degree based upon a theory of extreme atrocity or cruelty, murder in the second degree, and on the lesser included offense of involuntary manslaughter. Woodward objected to the involuntary manslaughter request, and asked that the jury be limited to considering the offense of murder. The judge agreed to her request which was an error (Massachusetts v. Woodward, 1998).

At the appeal of the defense and over the objection of the prosecution, the trial judge did not give the jury the option to return a verdict of guilty of the lesser-included offense of involuntary manslaughter. This left the jury with the possibility of wither first or second degree murder, or not guilty. After a long deliberation, the jury convicted Ms. Woodward of second degree murder. Ten days later, the trial judge permitted a defense motion to reduce the verdict to manslaughter. The court then sentenced Woodward to the nine months that she had already served while awaiting and standing trial and released her (Commonwealth of Massachusetts v. Louise Woodward, 2008).

The prosecution and defendant challenged the judgment of the Superior Court of Massachusetts. The prosecution wanted reinstatement of the jury's verdict of murder in the second degree or in the alternative resentencing of defendant by the court or remand for resentencing by another trial judge. The defense appealed the trial court's refusal to dismiss the indictment and the denial of her motion for a required finding of not guilty (Commonwealth v. Woodward, 1998).

The prosecution appealed the lessening of the verdict to manslaughter and the time-served sentence to the Massachusetts Supreme Judicial Court. Ms. Woodward also appealed her conviction. She disputed that the neuropathology evidence scientifically prohibited a guilty finding and that the case should have been dismissed because the prosecution had deprived her experts of access to crucial physical evidence, including pieces of dura and the skull fracture. She also brought up other issues of trial error, but stated that these claims need be considered by the court only in the event that the reduction in the verdict or the sentence was overturned. In other words, Louise Woodward preferred to accept the reduced manslaughter verdict and time-served sentence and return to her native England, rather than remain in Massachusetts for… READ MORE

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