SJC Affirms Felony-Murder Conviction Built on Joint-Venture Theory: Commonwealth v. Henderson (SJC-13482, September 4, 2026)

A jury convicted Kaiden Henderson of first-degree murder on a felony-murder theory, finding that he participated in an armed robbery during which his associate stabbed a marijuana dealer seventeen times. The Supreme Judicial Court affirmed on September 4, 2026, holding that the Commonwealth presented sufficient evidence of a planned robbery and that Henderson shared the intent to kill or cause grievous bodily harm.

Henderson argued on appeal that the evidence was insufficient and that the trial judge erred by not instructing the jury on larceny as a lesser offense. The SJC rejected both arguments and declined to grant relief under G. L. c. 278, § 33E.

The Night of the Stabbing

On November 21, 2020, Henderson, David Trongeau, and Devaughn Johnson drove from a Haverhill hotel to a nearby apartment building where Jose Vasquez lived with his family. Vasquez dealt marijuana and was friendly with Henderson and Johnson. Henderson and Trongeau entered the building while Johnson stayed in the back seat with the headlights and taillights on. The defendant parked around the corner despite ample space in front of the building.

Vasquez’s sister let the two men into the apartment. They went into Vasquez’s bedroom. At some point Trongeau briefly left the room to use the bathroom. Shortly after he returned, a crashing sound was heard, and Vasquez stumbled out bleeding from his neck and arms. He died from multiple sharp force injuries to his neck, chest, ribs, and torso.

Henderson and Trongeau fled. Henderson carried two bags over his shoulders that he did not have when he entered. Trongeau held a knife in his hand. They ran to the car, Johnson opened the doors, and the defendant sped away. When they returned to the hotel, Johnson opened a side door for Henderson and Trongeau, both of whom had blood on their clothes. Henderson changed and threw his bloody clothing in a hallway trash can.

Two men arrived at the hotel room to buy marijuana and found Henderson, Johnson, and Trongeau in a panic. Henderson and Johnson gave them marijuana in exchange for a ride. Henderson was dropped at a New Hampshire fast food restaurant, where a friend picked him up. Trongeau later told his girlfriend, Aspasia Filiogiannis, that he and Vasquez started arguing and he blacked out and stabbed Vasquez in the neck.

The Evidence

Police found blood throughout the apartment. Inside a locked safe in Vasquez’s bedroom was $2,730 in cash and papers with street terms for types of marijuana written on them. The victim’s father reported that between $15,000 and $30,000 in cash was missing.

Officers recovered Henderson’s bloody clothes from the hotel dumpster. DNA testing matched blood on his jeans and underwear to Vasquez. Blood was also found on sheets, the door handle, and the floor of the hotel room.

Police retrieved a multicolor backpack from a garbage truck that had collected trash from a Taunton apartment where Trongeau was later arrested. The backpack had blood on it and contained pre-rolled marijuana cigarettes and a digital scale. This backpack had belonged to Vasquez.

Henderson was arrested in a Boston hotel approximately ten days after the stabbing. He had $346 in cash, a blue Nike backpack with personal effects, identification cards in his own name and in the name Jacob Alves, and a one-way bus ticket to South Carolina in the name Jacob Alves. No murder weapon was recovered.

The medical examiner testified that Vasquez sustained seventeen knife wounds. Two different types of wounds were present: some with one sharp and one blunt edge consistent with a chef knife, and others with two sharp edges. Blurry video footage from the apartment building doorway showed Henderson and Trongeau entering and leaving. The jury could have found that Henderson had a knife clipped to his front pocket when he entered and was holding a knife when he fled.

What the Court Held

The SJC affirmed the conviction. Reviewing the evidence in the light most favorable to the Commonwealth, the court held that a rational jury could have found each element of felony-murder beyond a reasonable doubt. The Commonwealth had to prove that Henderson knowingly participated in an armed robbery during which a death occurred and that he had the intent to kill, to cause grievous bodily harm, or to do an act creating a plain and strong likelihood of death.

The court found sufficient evidence of a planned robbery. The jury could infer that Johnson and Henderson went to Vasquez’s apartment to obtain marijuana to sell to customers. Vasquez had the exact type of high-grade marijuana that Johnson advertised and they later gave to buyers. Henderson parked around the corner despite available spaces in front. He and Trongeau walked to the apartment, leaving Johnson in the car with lights on. When they fled, Johnson immediately opened the car doors and Henderson sped away. The defendant was carrying two bags that did not belong to him, one containing marijuana.

The evidence also supported a finding that Henderson was armed or knew Trongeau was armed. The two types of knife wounds suggested two weapons. The blurry video footage could have shown Henderson with a knife. Blood containing Vasquez’s DNA was found on the back of Henderson’s underwear, consistent with placing a knife in the back of his pants after the attack. Even if the jury did not find Henderson personally wielded a knife, his continued participation after the stabbing began demonstrated he shared Trongeau’s intent to kill or cause grievous bodily harm.

Henderson argued that the jury’s failure to convict him under theories of deliberate premeditation or extreme atrocity meant the jury rejected the theory that he participated in the stabbing. The court disagreed, stating it would not speculate about jury deliberations.

The Larceny Instruction

Henderson also argued that the trial judge erred by not instructing the jury on larceny as a lesser included offense of armed robbery. The SJC found no error. Although Henderson did not request such an instruction, he argued on appeal that the failure to give it sua sponte created a substantial likelihood of a miscarriage of justice.

The court noted that a larceny instruction would have contradicted Henderson’s trial strategy. He testified that he accidentally grabbed the wrong backpack while panicking after seeing Trongeau stab Vasquez, and that he ran because he was scared of Trongeau. To convict on larceny, the jury would have had to find intent to permanently deprive Vasquez of the property, which would have undermined Henderson’s defense that he took nothing intentionally. Trial counsel made a tactical decision not to pursue larceny as a lesser offense, and that decision was not manifestly unreasonable.

Why It Matters

The decision illustrates how Massachusetts courts apply joint-venture liability in felony-murder cases. A defendant can be convicted of felony-murder even without directly causing the death, if he knowingly participated in the underlying felony and shared the requisite intent. The Commonwealth may prove that intent through circumstantial evidence such as planning, coordinated actions, and consciousness of guilt.

The case also shows the limits of the requirement to instruct on lesser included offenses. When defense counsel pursues an acquittal strategy rather than seeking conviction on a reduced charge, trial judges need not provide instructions that would undermine that strategy. The defendant wanted the jury to believe he was an innocent bystander who took nothing intentionally. A larceny instruction would have invited the jury to reject that story and convict on a theft theory.

Henderson’s co-defendant Trongeau died before trial, and the Commonwealth entered a nolle prosequi of his indictments. Johnson, who remained in the car, was convicted of accessory after the fact to armed robbery. The Appeals Court affirmed that conviction in an unpublished 2025 decision.

Read the full opinion: Commonwealth v. Henderson (SJC-13482, September 4, 2026).