The Massachusetts Supreme Judicial Court has denied a second motion for a new trial filed by Dennis M. Bateman, who was convicted of two counts of first-degree murder in the 2005 deaths of Brandy Waryasz and her viable, unborn child. The case has been through extensive appellate review, with Bateman filing multiple challenges to his convictions over nearly two decades.
Bateman was originally indicted on July 8, 2005, in Franklin County Superior Court for the murders. Following his conviction, he filed his first motion for a new trial and appealed his convictions. The Supreme Judicial Court initially remitted that motion to the Superior Court for review.
The motion judge, who was also the trial judge, denied the first motion for a new trial. Judge John A. Agostini presided over the hearing on that motion, which was filed on Dec. 4, 2020. Bateman then appealed that denial, leading to a consolidated appeal that included both his direct appeal from the convictions and the appeal from the denial of his first new trial motion.
In 2023, the Supreme Judicial Court issued a comprehensive ruling in *Commonwealth v. Bateman*, affirming both the murder convictions and the denial of the first motion for a new trial. The court also declined to grant extraordinary relief under General Laws chapter 278, section 33E, which allows the court to reduce a sentence or order a new trial in capital cases if justice so requires.
However, while that consolidated appeal was still pending before the high court, Bateman filed a second motion for a new trial. He subsequently amended that motion twice before the Supreme Judicial Court issued its rescript in the consolidated appeal. The court then remitted this second motion to the Superior Court for initial review, following standard procedure.
The case involves serious allegations related to evidence disclosure, witness credibility, and expert testimony. Court records indicate the proceedings have involved questions about sound recordings, exculpatory evidence, impeachment of witness credibility, and expert opinions. These issues reflect common grounds for new trial motions in complex murder cases, where defendants often challenge the adequacy of evidence disclosure and the reliability of key testimony.
Amy L. Codagnone represented Bateman throughout the proceedings, while Assistant District Attorney Steven E. Gagne handled the case for the Commonwealth. The representation reflects the serious nature of the charges and the complexity of the legal issues involved.
The Supreme Judicial Court's recent decision, authored by Justice Kafker, represents the latest chapter in what has been extensive post-conviction litigation. Justice Kafker was joined by Chief Justice Budd and Justices Wendlandt, Georges, and Wolohojian in the court's review of the case.
Bateman's convictions stem from what prosecutors alleged was the deliberate killing of Waryasz and her unborn child. Massachusetts law treats the killing of a viable fetus as a separate count of murder, which explains the two first-degree murder convictions in this case. The prosecution had to prove that the fetus was viable at the time of the killing and that Bateman acted with premeditation and deliberation.
The case highlights the challenges defendants face in securing new trials, particularly in murder cases where the evidence has been thoroughly reviewed multiple times. Massachusetts courts require defendants to demonstrate that newly discovered evidence or legal errors warrant overturning convictions, a high standard designed to ensure finality in criminal proceedings while protecting defendants' rights.
The denial of Bateman's second new trial motion appears to close another avenue of appeal in this long-running case. However, defendants in capital cases may still pursue other forms of post-conviction relief, including potential federal habeas corpus proceedings, depending on the specific legal issues involved.
The Supreme Judicial Court's handling of this case demonstrates the court's methodical approach to reviewing complex murder convictions. The court has now twice examined Bateman's claims and found them insufficient to warrant a new trial, while ensuring that all legal challenges received proper consideration through the remand process.
This case serves as an example of how the Massachusetts appellate system handles serious criminal convictions, balancing the need for thorough review of legal challenges with the principle of finality in criminal judgments. The multiple motions and appeals reflect both the gravity of the charges and the defendant's persistent efforts to challenge his convictions through available legal channels.