Commonwealth v. Rodriguez
467 Mass. 1002
Mass.2014Background
- In 2003–2012 Annie Dookhan worked as a chemist at the Hinton State Laboratory; in 2011–2012 investigations revealed widespread evidence tampering and other misconduct by Dookhan. Dookhan later pleaded guilty to multiple crimes related to her lab work.
- Geordano Rodriguez was charged in Boston Municipal Court with possession with intent to distribute a class A drug (heroin), a school-zone enhancement, and marijuana possession; samples from his arrest were tested at the Hinton lab and the certificate bore Dookhan’s signature as an assistant analyst.
- On January 10, 2006 Rodriguez entered an admission to sufficient facts (treated as a guilty plea) to two counts and was sentenced to one year of probation and community service; one count was reduced and a school-zone count was dismissed.
- In November 2012 Rodriguez moved under Mass. R. Crim. P. 30(b) to withdraw his pleas, arguing the pleas were not knowing and voluntary due to Dookhan’s misconduct, that the misconduct was newly discovered exculpatory evidence, and that the Commonwealth failed to disclose material exculpatory evidence.
- The trial judge denied the motion after a hearing, making no written factual findings; Rodriguez appealed directly to the Supreme Judicial Court, which considered Rodriguez’s claim in light of its decision in Commonwealth v. Scott.
- The SJC concluded that (1) a conclusive presumption applies that Dookhan’s misconduct occurred and was egregious and attributable to the Commonwealth; but (2) Rodriguez must still show a reasonable probability he would have gone to trial (i.e., his plea was not knowing and voluntary). The denial was vacated and the case remanded for findings on that point.
Issues
| Issue | Rodriguez's Argument | Commonwealth's Argument | Held |
|---|---|---|---|
| Whether Dookhan’s misconduct renders prior guilty pleas involuntary | Dookhan’s lab misconduct means pleas were not knowing/voluntary; would have gone to trial | No direct link between lab misconduct and Rodriguez’s plea; plea stands despite later discoveries | Court presumed misconduct occurred and was egregious but remanded for findings whether Rodriguez would have proceeded to trial (reasonable probability) |
| Whether misconduct is newly discovered exculpatory evidence warranting withdrawal | Misconduct is newly discovered evidence that casts doubt on guilt | Evidence of misconduct is unrelated to individual cases unless a specific connection is shown | Court treated misconduct as presumptively applicable to cases tested by Dookhan but required movant to show reasonable probability of different choice |
| Whether Commonwealth failed to disclose Brady material pre-plea | Failure to disclose Dookhan’s misconduct violated due process and undermined plea | No obligation to overturn pleas based on evidence discovered years later absent a showing of prejudice | Court held misconduct was attributable to Commonwealth but remanded to determine prejudice/impact on voluntariness of plea |
| Standard for granting withdrawal of plea (Mass. R. Crim. P. 30(b)) | Movant entitled to new trial if justice not done; here justice not done due to tainted evidence | Motion for new trial is discretionary; denial reviewed for abuse of discretion | Court vacated denial and remanded for the judge to make findings under the Rule and Scott precedent |
Key Cases Cited
- Commonwealth v. Charles, 466 Mass. 63 (2013) (addresses challenges to convictions in light of Hinton lab issues)
- Luk v. Commonwealth, 421 Mass. 415 (1995) (an admission to sufficient facts is treated as a guilty plea)
- Commonwealth v. Furr, 454 Mass. 101 (2009) (motion to withdraw guilty plea treated as motion for new trial under Mass. R. Crim. P. 30(b))
- Commonwealth v. Grace, 397 Mass. 303 (1986) (standard that a judge may grant a new trial if it appears justice may not have been done)
- Commonwealth v. Russin, 420 Mass. 309 (1995) (motion for new trial committed to judge’s discretion)
- Commonwealth v. Robideau, 464 Mass. 699 (2013) (appellate review of denial of new trial for significant error of law or abuse of discretion)
- Commonwealth v. Duquette, 386 Mass. 834 (1982) (treatment of admissions to sufficient facts and plea-related procedures)