Self-Defense, Castle Law, and Jury Bias: Lessons from Commonwealth v. James Andrews, 24-P-430 (2025)
On June 16, 2025, the Massachusetts Appeals Court issued a decision in Commonwealth v. James Andrews, a complex and high-stakes homicide case that involved self-defense claims, the state’s "castle law," and constitutional questions about jury impartiality and effective assistance of counsel. For criminal defendants in Massachusetts—particularly those charged with violent crimes—this case offers valuable insights into the limits of self-defense, how courts evaluate evidence of mitigation, and what it takes to secure a fair trial.
As a Boston criminal defense attorney, understanding appellate rulings like this is critical to protecting your clients' rights. This post breaks down the facts, legal issues, and appellate findings in Commonwealth v. Andrews, while highlighting what the case means for anyone facing murder or assault charges in Massachusetts.
Overview: What Was the James Andrews Case About?
In 2018, James Andrews fatally stabbed Allan Monteiro, a man with whom he was sharing living space in a Bristol County apartment. Following a jury trial in Superior Court, Andrews was convicted of:
Murder in the second degree, and
Assault and battery by means of a dangerous weapon (ABDW).
On appeal, Andrews raised multiple arguments. He claimed he acted in self-defense, that the jury should have been instructed on the "castle doctrine" under G.L. c. 278, § 8A, and that the trial judge and his defense lawyer erred in handling a potentially biased juror. He also challenged evidentiary rulings, the prosecutor’s closing remarks, and his dual convictions for both murder and ABDW.
The Appeals Court affirmed his convictions. But in doing so, it addressed several issues that frequently arise in violent crime trials—and clarified the boundaries of key defenses.
The Facts: What Happened on August 9, 2018?
James Andrews and Allan Monteiro were living on the same floor of an apartment in Taunton. The leaseholder was a relative of both men, and Andrews was staying on a stairway landing separated from the hallway by a makeshift curtain. Monteiro occupied a room nearby, and his daughter and infant granddaughter were also living in the apartment.
In the early morning hours, Andrews was playing loud music and watching pornography. Monteiro’s daughter, whose baby was sick, asked him to turn it down. When Andrews didn’t respond, Monteiro confronted him. He tore down the curtain and smashed Andrews' laptop with a metal object.
The prosecution’s evidence showed that Monteiro then began walking back toward his room, attempting to de-escalate. Andrews grabbed a knife and followed Monteiro. Moments later, witnesses saw Monteiro lying on the ground with multiple stab wounds. Andrews fled the scene and later posted a cryptic and remorseful message on Facebook.
He was arrested later that day. The murder weapon was never found.
Key Legal Issues on Appeal
1. Castle Law: Was Andrews Entitled to a No-Duty-to-Retreat Instruction?
One of Andrews’ primary arguments on appeal was that he should have received a jury instruction under Massachusetts’ castle law (G.L. c. 278, § 8A). This law relieves a person of the duty to retreat when facing a threat in their own dwelling.
But the Appeals Court ruled that Andrews wasn’t entitled to the instruction. Why? Because Monteiro wasn’t an intruder—he was also lawfully residing in the apartment with the leaseholder’s permission.
Even though Monteiro entered Andrews’ makeshift sleeping area without invitation, the court found that the relevant “dwelling” was the shared apartment, not the curtained-off corner of the stairwell. Since Monteiro was not “unlawfully” in the dwelling, the castle doctrine didn’t apply.
Takeaway for Boston criminal defense attorneys: Castle doctrine defenses are limited to confrontations involving unlawful intrusions. In shared residences, co-occupants or invited guests are not considered trespassers, even if they enter another person’s room without consent.
2. Self-Defense: Did Andrews Reasonably Believe He Was in Danger?
Andrews also claimed that he acted in self-defense when he stabbed Monteiro.
Massachusetts law allows the use of deadly force in self-defense only if a person:
Actually and reasonably believes they are in immediate danger of death or serious injury,
Uses no more force than necessary, and
Tries to avoid the conflict, including retreating if possible (unless excused under the castle law).
The Appeals Court found that none of these elements were satisfied. According to the Commonwealth’s evidence:
Monteiro had walked away from the confrontation after damaging the laptop,
He was unarmed, and
Andrews pursued him, armed himself, and stabbed him multiple times.
Key lesson: Even if a victim initiates a conflict, a defendant cannot pursue and escalate it and then claim self-defense. Once the threat subsides, the duty to retreat and de-escalate is triggered.
3. Voluntary Manslaughter: Did Mitigation Apply?
At trial, the jury was instructed on voluntary manslaughter as a lesser included offense. On appeal, Andrews argued that the jury should have convicted him of voluntary manslaughter instead of murder.
The Appeals Court disagreed. To reduce a murder charge to voluntary manslaughter, a defendant must show mitigating circumstances, such as:
Reasonable provocation,
Sudden combat, or
Excessive force in self-defense.
Here, the court concluded that Andrews failed to meet any of those thresholds. Monteiro smashing the laptop, while arguably provocative, did not rise to the level of reasonable provocation for a deadly attack. The evidence also showed that Monteiro did not strike Andrews or engage in mutual combat. And since Andrews was not legally justified in using deadly force at all, he could not claim excessive force in self-defense.
4. Juror Bias and Ineffective Assistance of Counsel
Another appellate issue concerned Juror No. 4, who, during voir dire, initially stated that people charged with crimes "must have done something" and expressed a preference that defendants testify. However, after further questioning, he assured the court that he would follow the law and apply the presumption of innocence.
The trial judge seated the juror, and defense counsel did not object.
On appeal, Andrews argued that the juror’s initial statements showed bias and that his lawyer was ineffective for not striking him.
The Appeals Court rejected both claims, emphasizing:
The juror credibly affirmed his impartiality under oath,
The judge made an explicit finding of indifference,
Defense counsel’s decision not to challenge the juror was not manifestly unreasonable.
Practical insight: Voir dire can reveal implicit biases, but appellate courts defer heavily to trial judges’ assessments of juror credibility. Counsel must act carefully during voir dire to preserve challenges, but not every equivocal answer justifies disqualification.
5. Evidentiary Rulings: Hearsay, Self-Serving Statements, and Photographs
The defense also objected to several evidentiary rulings:
The trial judge allowed the Commonwealth to introduce Andrews’ Facebook post (a remorseful message referencing “the ultimate mistake”), but excluded other statements he made to friends claiming self-defense.
The Appeals Court held that these other statements were inadmissible hearsay, not part of the same conversation as the Facebook post, and not admissible under the doctrine of verbal completeness.
The defense also argued that the excluded statements should have been admitted under the due process exception established in Chambers v. Mississippi. The court rejected this, finding no persuasive guarantees of trustworthiness.
Separately, the Commonwealth introduced a photo of a knife similar to a machete that Andrews had possessed a week before the murder. The photo was used to show the kind of weapon that could have inflicted the wounds. Although the knife was not the murder weapon, and its admission may have been questionable, the Appeals Court found no prejudice warranting reversal.
6. Prosecutor's Closing Argument: Inflammatory or Fair?
Andrews also challenged the prosecutor’s closing as inflammatory and speculative, particularly language describing the attack as “savage” and the defendant as “carving up” the victim.
But the court found that:
The language, while graphic, was based on the evidence—including the autopsy and witness testimony,
Prosecutors are allowed to use strong, emotional rhetoric to highlight the gravity of the crime, and
No new facts were introduced; the argument stayed within the bounds of reasonable inference.
7. ABDW Conviction: Duplicative of Murder?
Andrews argued that his conviction for assault and battery by means of a dangerous weapon should have been vacated as duplicative of the murder conviction.
But under Massachusetts law, the two charges involve distinct elements:
Murder requires proof of death and malice,
ABDW requires proof of a touching with a dangerous weapon causing serious injury.
Since each crime contains an element the other does not, they are not duplicative, and sentencing on both was proper.
8. Motion to Reduce the Verdict: Rule 25(b)(2)
Finally, Andrews filed a postconviction motion to reduce the verdict from second-degree murder to voluntary manslaughter under Mass. R. Crim. P. 25(b)(2), which allows a judge to reduce a jury verdict “in the interest of justice.”
The trial judge denied the motion, and the Appeals Court upheld that decision. The judge concluded that the evidence did not support a finding of reasonable provocation, particularly since the victim had withdrawn from the confrontation when Andrews attacked.
Key point: Rule 25(b)(2) motions are granted sparingly. Judges must weigh the evidence in its totality, but are not obligated to second-guess a jury's well-supported verdict.
Why Commonwealth v. Andrews Matters for Criminal Defense in Massachusetts
This decision illustrates how Massachusetts courts handle difficult cases involving violence between co-occupants, claims of self-defense, and defense strategies at trial. Several important principles emerge:
1. Self-defense requires more than subjective fear.
Even if a defendant feels threatened, the belief must be objectively reasonable, and the response must be proportional and necessary. Courts look carefully at whether a defendant could have safely retreated or deescalated.
2. Castle doctrine defenses are limited to unlawful intrusions.
In cases involving shared residences, asserting “castle law” immunity from retreat obligations is only available when the victim was unlawfully in the dwelling—not merely unwelcome.
3. Juror rehabilitation is often sufficient.
If a juror initially expresses doubt about the presumption of innocence but later credibly affirms impartiality, courts are unlikely to find bias. Trial counsel’s decisions during voir dire are judged under a “manifestly unreasonable” standard, not in hindsight.
4. Strategic evidentiary rulings matter.
A defendant’s own statements may be excluded as hearsay unless they satisfy a recognized exception. And attempts to admit self-serving statements under “verbal completeness” will fail if the statements are made at a different time or are not directly related to the admitted evidence.
Facing Homicide or Assault Charges in Massachusetts?
If you’ve been charged with murder, manslaughter, or assault and battery with a dangerous weapon, your defense begins long before the trial. From voir dire to jury instructions, every detail matters.
At our Boston criminal defense law firm, we have the experience, trial skill, and legal knowledge to challenge the Commonwealth’s case and protect your rights. We’ll evaluate whether self-defense or mitigation is available and fight to ensure that no unfair jury or improper evidence seals your fate.