Posted: May 24th, 2022
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 an undetermined additional period of time in order to stand trial again (Commonwealth of Massachusetts v. Louise Woodward, 2008).
Woodward’s legal team filed motions after her conviction to the trial court for which a hearing began on November 4th. In the days following the verdict it came out that the jury had been split about the murder charge, but those who had favored an acquittal were persuaded to accept a conviction. This fact was of no legal consequence, however. On November 10th, at a post-conviction relief hearing, Judge Hiller B. Zobel reduced the conviction to involuntary manslaughter, saying that the circumstances in which the defendant acted were characterized by confusion, inexperience, frustration, immaturity and some anger, but not malice in the legal sense supporting a conviction for second-degree murder. He also said that he thought that allowing this defendant on this evidence to remain convicted of second-degree murder would be a miscarriage of justice (Commonwealth of Massachusetts v. Louise Woodward, 2008).
Woodward’s sentence was reduced to time served. In the area of criminal law, time served is a sentence where the defendant is credited immediately after the guilty verdict with the time spent awaiting trial. The time is generally taken away from the sentence, with only the balance being served after the verdict. She served a total of 279 days and was freed. The Assistant District Attorney then appealed the judge’s decision to the Supreme Judicial Court of Massachusetts. Woodward’s lawyers also appealed to the court to throw out her manslaughter conviction. The court confirmed the guilty verdict and the reduction in conviction to involuntary manslaughter by a 7-0 vote. In a 4-3 split decision the court discarded the prosecution’s appeal against the reduction of the conviction to involuntary manslaughter, and the sentence 16 June 1998 (Louise Woodward, 2009).
After all seven justices rejected the Commonwealth’s claim that the trial judge did not have the authority to reduce the verdict to manslaughter and the time-served sentence was upheld by a 4-3 vote, Louise Woodward returned to her home in England. “She is now studying law in London, having become convinced, by her own trial, on the critical importance of fair legal procedures to safeguard liberty and justice” (Commonwealth of Massachusetts v. Louise Woodward, 2008).
This case seemed to have a lot of issues right from the beginning. With the trial judge erring by not instructing the jury to consider the lesser charge of manslaughter as the prosecution had requested justice was not served as it should have been. Unless both sides are permitted to exercise their rights to the fullest extent provided by law then true justice can not be had. The rules have been set down in our justice system in order to protect the rights of both sides and to make sure that the best possible outcome is obtained. In this case that did not happen.
A little boy died and not matter how much arguing was done back and forth between the prosecution and the defense he will not be brought back to life. The best possible outcome that can happen from that point forward is that it be determined who was responsible for his death and the appropriate punishment be handed down. In this case the jury had originally convicted Louise Woodward of second degree murder. This would lead a reasonable person to conclude that there was indeed enough evidence to say that Louise Woodward was responsible for the death of Matthew Eappen. Having the second degree murder conviction reduced to involuntary manslaughter can be seen as appropriate since this was something that the prosecution had originally to be considered, but reducing her sentence down to time served does not seem to promote the idea that justice was indeed served in this case.
“Commonwealth of Massachusetts v. Louise Woodward.” (2008). 22 February 2010,
Commonwealth v. Woodward. 427 Mass. 659 (Mass. 1998). LexisNexis Academic. Web. 22
“Louise Woodward.” (2009). 22 February 2010,
“Massachusetts v. Woodward.” (1998). 22 February 2010,
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