Commonwealth v. Ruffin, SJC 12079

Wayne L. Ruffin pleaded guilty on July 26, 2007 to two counts of distribution of cocaine; two §32J counts were dismissed.
The seized substances were tested on October 3, 2007 at the William A. Hinton State Laboratory Institute.
Annie Dookhan signed the certificates of drug analysis as one of two "assistant analysts."
After revelations of Dookhan's lab misconduct, Ruffin moved for a new trial seeking to vacate his guilty pleas; the motion judge denied relief.
Ruffin appealed the denial, arguing his pleas were not knowing and voluntary because he was unaware of Dookhan's involvement or misconduct at the time of plea.
The court analyzed the claim under the Ferrara two‑prong framework and distinguished Commonwealth v. Scott because Dookhan’s signature on the lab certificate postdated Ruffin’s plea.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Ruffin's guilty pleas could be vacated based on Dookhan's misconduct	Ruffin argued his pleas were involuntary because he did not know Dookhan tested the drugs and her misconduct may have infected his case	The Commonwealth argued there was no evidence Dookhan's misconduct occurred before the plea or affected Ruffin's decision to plead	Court held Ruffin failed to satisfy Ferrara's first prong because Dookhan's involvement postdated the plea, so Scott's conclusive presumption does not apply; denial affirmed

Commonwealth v. Scott, 467 Mass. 336 (Mass. 2014) (establishes conclusive presumption of egregious misconduct when Dookhan signed a certificate dated before the plea)
Ferrara v. United States, 456 F.3d 278 (1st Cir. 2006) (two‑prong analysis for vacating pleas based on governmental misconduct)
Commonwealth v. Furr, 454 Mass. 101 (Mass. 2009) (pleas must be intelligently and voluntarily made)