Commonwealth v. Tyler

Summary

The court affirmed the defendant's first-degree felony-murder conviction and the denials of his two new-trial motions, holding that the later limitation on felony-murder liability did not apply retroactively, counsel was not ineffective for failing to request an involuntary-manslaughter instruction, and the jury instruction adequately required a risk to human life greater than the risk required for manslaughter. The court also declined extraordinary relief under § 33E, but vacated the duplicative assault-with-intent-to-rob conviction.