Commonwealth v. Watt

Summary

The Massachusetts Supreme Judicial Court reversed the Superior Court’s denial of Nyasani Watt’s motion for a new trial, holding that the defendant was constitutionally deprived of counsel because his trial attorney fell asleep during significant portions of the trial. The Court found the issue to be new and substantial under G.L. c. 278, §33E, and determined the error constituted structural error creating a substantial risk of miscarriage of justice, warranting a new trial.