Guzman v. Commonwealth, 458 Mass. 354

Guzman was convicted of trafficking, distribution, and conspiracy to distribute cocaine and later had these convictions vacated after about four years in prison.
He filed a civil claim against the Commonwealth under G. L. c. 258D, seeking monetary relief for erroneous conviction.
The Commonwealth moved to dismiss for lack of subject-matter jurisdiction and for failure to state a claim; the court treated it as summary judgment.
The Superior Court granted summary judgment against Guzman, holding he did not meet eligibility under § 1(B)(ii).
The Appeals Court reversed and reinstated Guzman’s claim, and the Supreme Judicial Court granted review to determine eligibility.
The Court holds that Guzman is eligible to seek relief under § 1(B)(ii) because his new-trial relief rested on grounds probative of innocence and the case is remanded for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether eligibility under § 1(B)(ii) requires grounds that tend to establish actual innocence.	Guzman argues relief was granted on grounds tending to establish innocence.	Commonwealth contends eligibility requires explicit or strong proof of innocence.	Eligibility does not require proof of actual innocence; grounds must tend to establish innocence.
Whether the grounds for Guzman’s new-trial relief rested on facts probative of innocence.	Guzman contends the new-trial relief was grounded in misidentification prejudicial to his defense.	Commonwealth argues grounds were not shown to directly establish innocence.	Relief rested on facts probative of Guzman’s innocence (misidentification issue).
Whether the legislative history supports a narrow or broad reading of eligibility.	Guzman favors a broad reading consistent with the statutory purpose.	Commonwealth advocates narrow interpretation to screen merits.	Legislative language supports a broader reading; eligibility need not rival merits testing.
Whether the trial judge’s judgment on new trial was appropriate to support eligibility.	Guzman contends the new-trial ruling, though based on ineffective assistance, still supports eligibility.	Commonwealth argues the grounds were not sufficient to show innocence.	Under § 1(B)(ii), the grounds are probative of innocence and support eligibility.

Commonwealth v. Grace, 397 Mass. 303 (1986) (evidence of new exculpatory factors may affect innocence considerations)
Commonwealth v. Alphas, 430 Mass. 8 (1999) (trial error may influence verdict; relevance to innocence)
Commonwealth v. Freeman, 352 Mass. 556 (1967) (test for material trial error; relevance to innocence proofs)
Commonwealth v. Laguer, 448 Mass. 585 (2007) (evidence issues and innocence considerations)
Commonwealth v. Healey, 438 Mass. 672 (2003) (evidence withheld; impact on innocence determination)
Loadholt, 456 Mass. 411 (2010) (recent appellate handling of evidence issues in innocence context)
Commonwealth v. Cohen (No. 1), 456 Mass. 94 (2010) (assessment of trial evidence and innocence considerations)
Commonwealth v. Mattei, 455 Mass. 840 (2010) (helpful discussion on evidentiary impacts on innocence)
Commonwealth v. Bacigalupo, 455 Mass. 485 (2009) (limitations on evidentiary use impacting innocence analyses)
Commonwealth v. Green, 420 Mass. 771 (1995) (trial error and innocence considerations)
Commonwealth v. Vizcarrondo, 427 Mass. 392 (1998) (legal standards for innocence-related relief)