Commonwealth v. Dayton
477 Mass. 224
| Mass. | 2017Background
- Timothy O. Dayton was charged in Superior Court with multiple motor-vehicle offenses, including two indictments alleging OUI (third offense), each asserting prior OUI convictions in 1988 and 1989.
- The Commonwealth moved under G. L. c. 276, § 58A for a dangerousness hearing seeking pretrial detention without bail.
- Dayton argued § 58A permits pretrial detention under the OUI clause only where the defendant has three prior OUI convictions (i.e., the current charge would be a fourth).
- A Superior Court judge initially denied the Commonwealth’s motion; a single justice ordered the hearing; after the hearing the judge found Dayton dangerous and ordered detention, then reported the legal question to the Appeals Court.
- Before resolution, Dayton pleaded guilty; the Supreme Judicial Court accepted transfer of the reported question to decide whether § 58A permits detention when a defendant has only two prior OUI convictions and is charged with OUI, third offense.
Issues
| Issue | Plaintiff's Argument (Commonwealth) | Defendant's Argument (Dayton) | Held |
|---|---|---|---|
| Whether § 58A permits pretrial detention when a defendant with two prior OUI convictions is arrested and charged with OUI, third offense | § 58A’s OUI clause authorizes detention when charged with an offense that could result in a third or subsequent OUI conviction (i.e., two priors suffice) | § 58A requires three prior OUI convictions before detention may be sought; the statutory language is ambiguous in defendant’s favor under the rule of lenity | No — § 58A is ambiguous and, under the rule of lenity, must be read to require three prior OUI convictions before detention without bail may be sought |
Key Cases Cited
- Commonwealth v. Young, 453 Mass. 707 (discussed availability of pretrial detention for charges that could result in a third OUI conviction)
- Commonwealth v. Dodge, 428 Mass. 860 (noting § 58A includes charges that could result in a third or subsequent OUI conviction)
- Commonwealth v. Constantino, 443 Mass. 521 (application of rule of lenity where statute is ambiguous)
- Commonwealth v. Daley, 463 Mass. 620 (statutory interpretation principle: no words should be treated as superfluous)
- Commonwealth v. Madden, 458 Mass. 607 (§ 58A’s focus on public safety and pretrial restraint, not punishment)
- Commonwealth v. Murchison, 428 Mass. 303 (explaining when courts should answer moot but recurring questions of law)