SJC Affirms Murder Conviction, Rejects Self-Defense Claims: Commonwealth v. Ramos (SJC-12678, August 13, 2026)

The Supreme Judicial Court affirmed Jose Ramos’s first-degree murder conviction for stabbing Luis Sanchez to death outside a Springfield shelter in 2015. Ramos claimed self-defense, arguing the victim attacked him first with a screwdriver. The court rejected his arguments that trial counsel was ineffective and that the judge erred by not instructing the jury on voluntary manslaughter by sudden combat.

The Facts

On the evening of March 10, 2015, Ramos and Sanchez were residents at a homeless shelter. Ramos reported to staff that Sanchez was drunk and causing problems, requesting that someone speak with Sanchez. A staff member told Ramos she would handle it and asked him to leave the office. Ramos headed to the basement; Sanchez followed.

Surveillance footage showed Ramos putting on a leather jacket in the basement dormitory and beckoning Sanchez to follow him upstairs. Sanchez removed his jacket and followed. The men walked past a second employee who had been sent to mediate their dispute. Neither man stopped to talk. The employee later testified that both men appeared hostile and were walking in a manner that suggested they were going to fight outside, where shelter residents would go to avoid being banned for fighting on the premises.

Video footage captured part of what happened next. As Sanchez walked toward the street with his back to Ramos and his arms at his sides, Ramos suddenly quickened his pace, closed the gap between them, and lunged at Sanchez with his arm raised in a slashing motion. Sanchez fell to the ground. The video did not capture the next fifteen seconds. A witness testified she saw Ramos make upward punching gestures at Sanchez, who was standing again and unarmed. She saw no weapon in Ramos’s hands but noticed Sanchez bleeding.

When the men came back into view, Ramos was walking away. Sanchez briefly moved toward Ramos, then removed his jersey and undershirt and collapsed. Forensic examination later revealed cuts in both shirts matching the wounds on Sanchez’s body, proving he was stabbed while wearing them.

Staff and a police officer assigned to the shelter found Sanchez bleeding heavily from the abdomen. Ramos was holding a knife, which he dropped on command. Police recovered a green-handled knife containing Sanchez’s DNA and a sheath from Ramos’s jacket pocket. They also recovered a screwdriver that tested positive for occult blood.

Ramos sat near the shelter entrance smoking a cigarette while Sanchez received medical attention. He was uninjured. His jacket had some damage but none of the tears penetrated the interior lining. When officers arrested him, he calmly finished his cigarette, stood, extinguished it, and turned around with his hands behind his back without being told to do so. As they walked past Sanchez’s body, Ramos remarked, “[T]hat guy’s dangerous. He always carried knives. I don’t feel bad about it.”

Sanchez died at the hospital. The medical examiner found four stab wounds: one to the back probing from back to front and slightly upward, two to the chest penetrating the heart, and one to the torso puncturing the lung and stomach. The cause of death was multiple sharp-force injuries.

The Defense Case

Ramos did not contest that he stabbed Sanchez. He argued that Sanchez attacked him first with a screwdriver and that he acted in self-defense. A shelter resident testified that he saw the men pushing and screaming in the parking lot when Sanchez pulled out a red-and-clear-handled screwdriver from his back and swung it at Ramos, prompting Ramos to strike back.

The resident’s testimony contradicted the surveillance video in key respects. He testified that Sanchez started swinging the screwdriver after removing his jersey and undershirt. The video showed Sanchez collapsing to the ground and remaining there immediately after removing his clothing. When shown photographs of the yellow-and-gray-handled screwdriver recovered from the scene (which tested positive for occult blood), the resident testified it was not the screwdriver he saw Sanchez use.

The Trial and Verdict

At the close of evidence, Ramos’s trial counsel withdrew his request for a voluntary manslaughter by sudden combat instruction, explaining that case law showed the instruction was unwarranted. The judge instructed the jury on self-defense, murder in the first degree (deliberate premeditation and extreme atrocity or cruelty), murder in the second degree, and voluntary manslaughter (excessive force in self-defense and reasonable provocation). On April 12, 2018, the jury convicted Ramos of murder in the first degree on a theory of deliberate premeditation.

The Motion for a New Trial

In May 2025, Ramos filed a motion for a new trial arguing that his trial counsel was constitutionally ineffective for failing to introduce evidence of Sanchez’s prior violent conduct under Commonwealth v. Adjutant, 443 Mass. 649 (2005). That decision permits a trial judge to admit evidence of a victim’s prior violent acts to support a self-defense claim where the identity of the first aggressor is in dispute.

Ramos sought to introduce Sanchez’s 2010 convictions for rape of a child and indecent assault and battery on a child under fourteen, a 2009 conviction for resisting arrest, and a 2007 conviction for assault and battery. Trial counsel submitted an affidavit explaining his decision not to introduce this evidence. He stated that based on his review of the surveillance video, there was no issue about who the first aggressor was. He also noted that Ramos had a more significant record for violence, including convictions for assault and battery and assault and battery by means of a dangerous weapon. Counsel believed that introducing Sanchez’s record would have opened the door to the Commonwealth introducing Ramos’s record, which would not have advanced his client’s interests.

The motion judge denied the motion without an evidentiary hearing. He concluded that trial counsel’s tactical decision was not manifestly unreasonable because the evidence provided little support for the notion that Sanchez had a propensity to be the first aggressor and would have permitted the Commonwealth to introduce Ramos’s prior violent conduct. The judge also questioned whether the trial judge would have allowed admission of Sanchez’s child sexual assault convictions, as those offenses were markedly dissimilar to the alleged conduct here.

What the SJC Held

The Supreme Judicial Court affirmed the conviction and the denial of the motion for a new trial. Writing for the court, Justice Wendlandt held that trial counsel’s strategic decision not to introduce Adjutant evidence was not manifestly unreasonable.

The court noted that the acts underlying Sanchez’s child sexual assault convictions, though perhaps indicative of violent behavior generally, had minimal probative value to show that Sanchez was likely to have been the first to employ deadly force. The prejudicial effect of these convictions may have outweighed their minimal probative value.

Even assuming the trial judge would have allowed the evidence, trial counsel’s decision to forgo it was not manifestly unreasonable. The defendant’s self-defense theory rested on whether he or Sanchez was the first to use a deadly weapon. The Adjutant evidence showed that Ramos was the only one with a conviction of assault and battery by means of a dangerous weapon. Counsel reasonably believed that any positive effect would be outweighed by the prejudicial effect of counter-evidence about Ramos’s violent history.

The Sudden Combat Instruction

The court also rejected Ramos’s argument that the trial judge should have given a voluntary manslaughter by sudden combat instruction even after trial counsel withdrew the request for it. Sudden combat applies when two people meet without intending to quarrel, angry words suddenly arise, and a conflict springs up with blows exchanged on both sides.

The evidence did not support such an instruction. Ramos and Sanchez had a preexisting dispute. Ramos reported the conflict to staff, who promised to send someone to resolve it. Rather than wait, Ramos put on a jacket containing a knife and beckoned Sanchez to follow him outside. The men passed a staff member without seeking help. The surveillance video showed Ramos ambushing Sanchez from behind as Sanchez walked away. The evidence showed this was a planned fight, not a sudden combat situation.

The court held that the trial judge was not required to give the instruction sua sponte after trial counsel specifically withdrew the request for it.

Why It Matters

The decision reinforces the limits of the Adjutant exception to the general rule against admitting prior bad acts. Trial counsel may reasonably decline to introduce a victim’s prior violent acts when doing so would open the door to more damaging evidence about the defendant’s own history of violence. The strategic calculus is particularly strong when the victim’s prior acts bear little resemblance to the conduct at issue and the defendant has a more extensive record of similar violence.

The case also clarifies that sudden combat instructions are not warranted when the evidence shows a planned confrontation rather than a spontaneous altercation. A preexisting dispute, advance preparation (such as retrieving a weapon), and an ambush-style attack all weigh against finding sudden combat. Trial judges need not give such instructions sua sponte when defense counsel affirmatively withdraws the request.

Finally, the decision demonstrates the power of surveillance video to contradict witness testimony. Here, the video footage directly undermined the defense witness’s account of the confrontation and supported the Commonwealth’s theory that Ramos was the aggressor who struck first.

Read the full opinion: Commonwealth v. Ramos (SJC-12678, August 13, 2026).