971 N.E.2d 843
Mass. App. Ct.2012Background
- Riley convicted in 1986 of manslaughter and related offenses as a joint venturer, reversed due to Bruton errors, and retried where acquitted.
- Bruton errors arose from admission of non-testifying codefendants' statements; the SJC later repudiated the Bruton approach.
- Riley filed a compensation claim under G. L. c. 258D after the retrial acquittal.
- G. L. c. 258D allows compensation if a conviction is reversed on grounds tending to establish the claimant’s innocence and later acquittal occurs.
- Guzman expanded the “grounds which tend to establish innocence” concept and Drumgold clarified the standard; Bacigalupo involved Bruton-related reversal.
- The trial reversal here was based on Bruton error, not on evidence tending to prove innocence, leading to ineligibility for compensation.
- The court reversed the dismissal and held Riley not eligible for G. L. c. 258D relief; the plaintiff’s claim was dismissed.
- Note: The opinion discusses eligibility criteria and the burden of proof for innocence under § 1(B) and § 1(C).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Bruton-based reversal qualifies as grounds tending to innocence | Riley argues reversal rests on innocence. | Commonwealth contends Bruton error does not show innocence. | No; Bruton-ground reversal does not establish innocence under §1(B). |
| Whether Guzman limits eligibility for Bruton-reversal cases | Guzman guidance supports eligibility when innocence is probative. | Guzman does not mandate eligibility for Bruton-based reversals. | Guzman guides but does not create categorical eligibility for Bruton cases. |
| Whether the presence of exculpatory evidence was enough to show innocence | Exculpatory evidence not suppressed; reversal based on admission of evidence of guilt. | Error affects credibility but not innocence necessity. | Reversal based on admitted evidence of guilt does not show innocence for §1(B). |
| Whether Drumgold/Bacigalupo compel eligibility despite Bruton grounds | Drumgold/Bacigalupo show relief where credibility/innocence issues were affected. | Those cases are distinguishable; here the reversal did not forestall the fact-finder on innocence. | Distinctions undermine eligibility under §1(B) for this Bruton-reversal case. |
| What is the court’s ruling on compensation eligibility in this Bruton-reversal case | Riley seeks relief under §258D. | Ineligibility under §1(B) as facts do not tend to prove innocence. | Not eligible; order denying judgment on the pleadings affirmed (novel outcome: dismissal of claim). |
Key Cases Cited
- Guzman v. Commonwealth, 458 Mass. 354 (2010) (defines eligibility; grounds must tend to establish innocence; discusses Bruton-related issues and legislative history)
- Guzman v. Commonwealth, 74 Mass. App. Ct. 466 (2009) (earlier articulation of innocence-relevant grounds)
- Drumgold v. Commonwealth, 458 Mass. 367 (2010) (new or undisclosed exculpatory evidence can render relief when it affects reliability of key testimony)
- Bacigalupo, 455 Mass. 485 (2009) (reversed conviction due to Bruton error; evidence not wholly passive but affects credibility)
- Commonwealth v. Cunningham, 405 Mass. 646 (1989) (reversed convictions due to Bruton error; discusses intent issue and probability of conviction)
- Bruton v. United States, 391 U.S. 123 (1968) (rule prohibiting use of non-testifying codefendant confessions against co-defendant)