Watts v. Commonwealth
468 Mass. 49
Mass.2014Background
- In March–August 2013 Ronald Watts and Kevin Aguirre (both 17 at the time of their alleged offenses) were charged in District Court; their cases were pending when St. 2013, c. 84 took effect on September 18, 2013.
- St. 2013, c. 84 raised the upper age in the Juvenile Court definitions from 17 to 18 and expanded Juvenile Court jurisdiction so many acts by 17‑year‑olds would be handled as juvenile, not adult, matters.
- Watts and Aguirre moved to dismiss their District Court criminal charges, arguing the new statute should be applied retroactively to remove District Court jurisdiction over cases of persons who were 17 when the offense was committed but whose proceedings began before Sept. 18, 2013.
- The trial courts denied relief; the petitioners filed a G. L. c. 211, § 3 petition to vacate the denials and the single justice reported the matter to the court, which ordered judgment denying relief and issued this opinion explaining why.
- The court concluded the Act was substantive (changed nature of proceedings and dispositions), so there is a presumption of prospective application; the Legislature did not clearly express intent to apply the Act retroactively to cases begun and pending before Sept. 18, 2013.
- The court rejected arguments based on the rule of lenity, the Act’s remedial purpose, and federal grant‑compliance pressures; prospective application was not repugnant to the statute’s purpose.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether St. 2013, c. 84 applies retroactively to criminal cases begun before and pending on Sept. 18, 2013, for persons who were 17 at time of the offense | The Act’s plain terms expand Juvenile Court jurisdiction to 17‑year‑olds and therefore should apply to pending cases; 17‑year‑olds should receive juvenile protections | The Act’s language and legislative history indicate it applies prospectively to proceedings begun on or after the effective date; substantive changes trigger presumption against retroactivity | Held: Act is not retroactive to cases begun before and pending on Sept. 18, 2013; prospective application governs |
| Whether the Act is merely procedural (so retroactivity favored) or substantive (presumption against retroactivity) | Act is jurisdictional expansion only, not penal, so it is not subject to penal retroactivity rules | Act changes nature of proceedings and dispositional options for juveniles, so it is substantive and implicates G. L. c. 4, § 6 rules for penal statutes | Held: Act is substantive; presumption of prospective application applies |
| Whether any clear legislative intent or statutory language overcomes presumption of prospectivity | The remedial purpose and legislative reports indicate lawmakers intended protection for 17‑year‑olds generally, implying retroactivity | No unequivocal statutory language or other retroactive provisions indicate clear legislative intent to reach pending cases; operative fact includes when proceedings "begun" | Held: No clear legislative intent to apply retroactively to pending cases |
| Whether prospective application is repugnant to the statute’s purpose (i.e., cannot accomplish legislative aims) | Delaying application defeats the statute’s child‑protection objective; federal grant conditions (PREA) demand segregation of <18s from adults | Legislature anticipated implementation needs (staffing, services); federal scheme allows phased compliance; prospective application is realistic and not contrary to purpose | Held: Prospective application is not repugnant to the Act’s purpose; therefore no exception to presumption applies |
Key Cases Cited
- Commonwealth v. Dotson, 462 Mass. 96 (discusses interpretation of amendments to penal statutes and prospectivity presumption)
- Nassar v. Commonwealth, 341 Mass. 584 (establishes rule that penal amendments are presumptively prospective absent clear retroactive intent)
- Commonwealth v. Galvin, 466 Mass. 286 (retroactivity allowed where Legislature clearly manifested intent and to avoid anomalous results)
- Commonwealth v. Bradley, 466 Mass. 551 (explains exceptions to prospectivity presumption: manifest legislative intent and repugnancy to statute’s context)
- Boston Edison Co. v. Massachusetts Water Resources Auth., 459 Mass. 724 (example of applying statutory amendment to pending cases where statute so provided)
- Metcalf v. Commonwealth, 338 Mass. 648 (explains legal/constitutional distinction between delinquency and adult crime)
- Commonwealth v. Connor C., 432 Mass. 635 (juvenile adjudication aims at rehabilitation and avoiding criminal stigma)
- Patrick v. Commissioner of Correction, 352 Mass. 666 (timing for when punishment or liability is considered incurred for prospectivity analysis)