Understanding Commonwealth v. Rateree: Self-Defense, Adjutant Evidence, and Duplicative Convictions in a Massachusetts SJC Case
What happens when self-defense collides with evidentiary limitations in a violent street brawl? In Commonwealth v. Shondell Q. Rateree, SJC-13599 (2025), the Massachusetts Supreme Judicial Court (SJC) addressed a complex criminal appeal from Barnstable County that touched on critical areas of criminal law: Adjutant evidence, duplicative convictions, and the limits of misleading a police officer charges.
This case—tried before Judge Mark Gildea in Massachusetts Superior Court—offers valuable insights for criminal defense attorneys in Massachusetts, especially those litigating self-defense or violent felony cases. It also raises important strategic considerations about jury instructions, trial evidence, and preserving issues for direct appellate review.
Let’s walk through what happened and why this case matters.
The Conflict: A Hyannis Altercation Turns Violent
The facts of the case involve an early morning altercation in Hyannis, Massachusetts. Four people were involved: defendant Shondell Rateree, his codefendant, a woman named Tyla Marceline, and her boyfriend, Christopher Griffiths. All four suffered knife wounds. Griffiths's injuries were the most serious—multiple stab wounds to the torso that nearly proved fatal.
The Commonwealth alleged that Rateree initiated a brutal attack, dragging Marceline by the hair and stabbing Griffiths with a knife. The defense argued both self-defense and defense of another, claiming Griffiths was the first to escalate the fight to deadly force.
Charges and Convictions
Rateree was charged with:
Mayhem (G.L. c. 265, § 14)
Assault with intent to maim (G.L. c. 265, § 15)
Assault and battery by means of a dangerous weapon (ABDW), including a knife and shod foot (G.L. c. 265, § 15A)
Simple assault and battery (G.L. c. 265, § 13A)
Misleading a police officer (G.L. c. 268, § 13B)
He was convicted of six counts and acquitted of others, including kidnapping and conspiracy. The Massachusetts SJC allowed direct appellate review, and the appeal focused on three key legal issues relevant to Massachusetts criminal defense attorneys.
Issue 1: Exclusion of Adjutant Evidence in Self-Defense
What is Adjutant Evidence?
Adjutant evidence refers to prior violent acts by the victim that may be admissible to show that the victim was the first aggressor—critical when a defendant claims self-defense. In Commonwealth v. Adjutant, 443 Mass. 649 (2005), the SJC held that if the identity of the first aggressor is in dispute, the defendant can offer specific prior acts of violence by the victim to support a self-defense claim.
The Rateree Motion
Defense counsel in Commonwealth v. Rateree moved to introduce evidence of a 2017 knife assault by Griffiths. The argument? That Griffiths had a history of violence and was likely the first to use deadly force. This is a classic Adjutant argument—one familiar to many Massachusetts criminal law practitioners.
The trial judge initially allowed voir dire of a witness about the prior incident but ultimately excluded the evidence, concerned it would open the door to damaging rebuttal evidence about the defendant’s prior armed robbery. The judge also concluded that Adjutant did not apply to defense of another, only self-defense.
The SJC’s Ruling
The SJC affirmed. The Court held that while there was a factual dispute over who used deadly force first, the trial judge did not abuse discretion in excluding the evidence. The potential prejudice to the defendant—due to the risk of rebuttal evidence—outweighed the limited probative value of the prior incident.
Moreover, the SJC declined to extend Adjutant to defense of another, noting the lack of support in other jurisdictions and the added complexity such an extension would introduce. For Massachusetts trial attorneys, this ruling draws a clear line: Adjutant evidence is still limited to self-defense claims, at least for now.
Issue 2: Misleading a Police Officer – When Is a Denial Criminal?
Rateree was convicted of misleading a police officer under G.L. c. 268, § 13B, a statute aimed at witness intimidation and obstruction. The charge stemmed from Rateree telling detectives he hadn’t been “down by the ocean”—even though he later threw his knife into the water at Bay View Beach in Yarmouth.
What counts as misleading a police officer?
This is a common question for criminal defense attorneys. In Massachusetts, a conviction under this statute requires:
A false or deceptive statement
Made with the specific intent to interfere with a criminal investigation
In Commonwealth v. Morse, 468 Mass. 360 (2014), the SJC held that simple denials—such as “I didn’t do it” or “I wasn’t there”—do not by themselves constitute a criminal offense under § 13B.
The SJC’s Analysis in Rateree
The Court found that Rateree’s vague and equivocal response—“Down by the ocean, no... I don’t think so”—was just a simple exculpatory denial. Without more, it lacked the specific intent needed to support a conviction.
The misleading conviction was vacated, reinforcing a key principle: Not every lie to police is a crime. For those practicing appellate criminal defense in Massachusetts, this ruling reinforces the importance of distinguishing content-laden lies from non-criminal denials.
Issue 3: Duplicative Convictions and Lesser Included Offenses
Another major win for the defense came on the issue of duplicative convictions. Rateree was convicted of both:
Mayhem
Assault with intent to maim
ABDW causing serious bodily injury
He was also convicted of both:
Simple assault and battery
ABDW by shod foot
Under Massachusetts law, a defendant cannot be punished for both a greater offense and a lesser included offense unless the acts are separate and distinct.
The Problem? No Jury Instruction on Distinct Acts
Although the evidence could have supported separate acts, the jury was never instructed that each charge must relate to a distinct criminal act. As a result, the SJC found a substantial risk of a miscarriage of justice.
Four convictions were vacated:
Assault with intent to maim
ABDW causing serious bodily injury
One count of assault and battery
Misleading a police officer (as discussed above)
This outcome is a critical reminder for trial lawyers in Massachusetts: When judges are charging a jury on lesser-included offenses, the jury must be clearly told they need to differentiate the underlying conduct.
Key Takeaways for Massachusetts Criminal Defense Attorneys
1. Adjutant Evidence Remains Narrow in Scope
It applies only to self-defense, not defense of another.
Judges have broad discretion to exclude it, especially where rebuttal risks outweigh the probative value.
2. Misleading a Police Officer Requires Specific Intent
Simple denials are not enough.
Unless there’s a deliberate attempt to derail the investigation, § 13B does not apply.
3. Duplicative Convictions Can Be Fatal—Even Without Objection
If no jury instruction requires separate acts, convictions for both greater and lesser offenses stemming from the same event must be vacated.
Conclusion: Rateree’s Impact on Massachusetts Criminal Practice
Commonwealth v. Rateree is more than a violent altercation turned courtroom drama—it’s a roadmap for litigating violent felonies, challenging evidentiary exclusions, and protecting clients from unconstitutional duplicative punishments.
For lawyers practicing criminal defense in Massachusetts, this case underscores the value of strategic restraint (especially with Adjutant evidence), the importance of preserving the record, and the need for vigilance during jury charge conferences.
It also reminds us that not every misstatement to police is a crime—and that the SJC is still willing to clarify and enforce those limits.