Murphy v. Commissioner of Correction, 493 Mass. 170

Conrad Murphy, convicted of several violent and sexual offenses, was sentenced to concurrent prison terms and, upon completing his sentence, was civilly committed as a sexually dangerous person (SDP) under Massachusetts law.
Murphy filed multiple petitions for discharge from civil commitment, all of which were denied after jury findings that he remained sexually dangerous.
In January 2022, Murphy petitioned the Massachusetts Department of Correction (DOC) for medical parole due to significant health issues, providing supporting medical documentation.
The DOC denied his petition, citing its policy that civilly committed individuals under G.L. c. 123A are ineligible for medical parole.
Murphy sought judicial review of the denial; a Superior Court judge found a due process violation and ordered DOC to hear his parole petition.
The DOC appealed, and the Supreme Judicial Court transferred and decided the case.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Applicability of Medical Parole	Medical parole statute should apply to civilly committed SDPs	Statute applies only to those serving criminal sentences	Medical parole statute does NOT apply to civilly committed SDPs
Due Process Rights	Denial of medical parole review violates substantive due process	SDPs have alternative review via §9; no due process violation	No due process violation; §9 process satisfies constitutional needs
Statutory Interpretation	Statute's definition of "prisoner" should include SDPs	"Prisoner" for parole excludes SDPs and pretrial detainees	"Prisoner" does not include civilly committed SDPs
Adequacy of §9 Review Procedures	§9 process is untimely and not medical-condition focused	§9 allows release if no longer sexually dangerous	§9 procedures do not violate due process; medical condition may be considered

Dutil, petitioner, 437 Mass. 9 (reiterates that G.L. c. 123A is a civil, not criminal, statute)
LeSage, petitioner, 488 Mass. 175 (discusses government interests in protecting the public from sexually dangerous persons)
Chapman, petitioner, 482 Mass. 293 (explains the discharge and review process under §9 for SDPs)
Bruno, Commonwealth v., 432 Mass. 489 (confirms lack of parole or less restrictive alternatives under G.L. c. 123A)
Fay, Commonwealth v., 467 Mass. 574 (outlines burden of proof for SDP discharge at trial)
Abner A. v. Massachusetts Interscholastic Athletic Ass'n, 490 Mass. 538 (describes standard of review under certiorari)
Buckman v. Commissioner of Correction, 484 Mass. 14 (describes legislative intent behind the medical parole statute)
Harmon v. Commissioner of Correction, 487 Mass. 470 (holds that medical parole does not apply to pretrial detainees and guides this decision)