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Massachusetts Supreme Judicial Court Explains Procedures of G. L. c. 278A and Rules That a Claim of Self-Defense Is a Claim of Factual Innocence

by Douglas Ankney

The Supreme Judicial Court of Massachusetts explained the procedures for filing and adjudicating a motion brought under G. L. c. 278A, which allows those convicted access to forensic and scientific testing of evidence that could potentially prove their innocence, and ruled that a defendant convicted of manslaughter asserted factual innocence when he alleged he did not commit manslaughter because he acted in self-defense.

Stanley Williams pleaded guilty to manslaughter in 2005. In 2018, he filed a motion pursuant to G. L. c. 278A (“278A motion”) requesting that clothing recovered from the victim be tested for gunshot residue and that shell casings recovered at the crime scene be tested for fingerprints.

Williams alleged in the affidavit accompanying the 278A motion that he grabbed the victim’s wrist when the victim pulled out a gun and pushed against the victim, at which time he heard two gunshots in close succession.

Williams stated in the 278A motion that forensic testing of the clothing and shell casings would show the weapon belonged to the victim and that Williams shot the victim at close range in self-defense.

The Commonwealth filed a response, arguing that Williams did not meet the 278A motion’s threshold requirement of claiming factual innocence because Williams claimed self-defense, which rendered him legally innocent but not factually innocent.

Additionally, the Commonwealth argued that a 278A motion must allege the requested analysis has the potential to result in material evidence as to the moving party’s identification as the perpetrator of the crime, and Williams’ motion failed because he was seeking evidence to show no crime was committed due to self-defense.

The superior court denied Williams’ motion “for the reasons set forth in the Commonwealth’s opposition.” The Supreme Judicial Court granted Williams’ application for direct appellate review.

The Court observed that only a defendant who “asserts factual innocence of the crime for which [he or she] has been convicted” is eligible to request postconviction forensic testing pursuant to chapter 278A. G. L. c. 278A, § 2. Defendants must satisfy the statutory requirements set forth in chapter 278A, which consist of two procedural stages: a motion stage and, if the motion is allowed, a hearing stage. Commonwealth v. Wade, 5 N.E.3d 816 (Mass. 2014).

At the motion stage, the individual seeking the analysis must provide, inter alia, “information demonstrating that the analysis has the potential to result in evidence that is material to the moving party’s identification as the perpetrator of the crime in the underlying case” and an affidavit “stating that [he or she] is factually innocent of the offense of conviction and that the requested forensic or scientific analysis will support the claim of innocence.” G. L. c. 278A, §§ 3(b)(4) and 3(d).

The motion stage is “essentially non adversarial.” Wade. If the court finds the motion stage requirements have been satisfied, then the Commonwealth files a response that “include[s] any specific legal or factual objections that [it] has to the requested analysis.” G. L. c. 278A, § 4(c).

The court will then hold an evidentiary hearing. Id. at § 6. The movant must establish at the hearing by a preponderance of the evidence each of the statutory requirements, including that “the requested analysis has the potential to result in evidence that is material to [his or her] identification as the perpetrator of the crime.” Id. at § 7(b). If such a demonstration is made, thecourt shall allow the analysis and the results may be used to support a motion for a new trial. Wade. The Court re-emphasized that the preliminary motion stage is non-adversarial, and it is not until the hearing stage that the defendant must prove the assertions made in the motion. Id.

The Court further observed that the Commonwealth’s position was both contrary to the Court’s self-defense jurisprudence and a misreading of Chapter 278A. Homicide may be lawful or unlawful. Commonwealth v. Webster, 59 Mass. 295 (1850).

Self-defense negates the element of “unlawful” homicide. Commonwealth v. Rodriguez, 352 N.E.2d 203 (Mass. 1976). When Williams asserted that he acted in self-defense, he asserted that he did not commit manslaughter – “the crime for which [he] has been convicted.” This assertion met the “factual innocence” requirement. And as to asserting the scientific analysis would result in evidence that is material to Williams’ identification as the perpetrator of the crime, his assertion that he acted in self-defense meant no crime occurred; consequently, the evidence would show he was wrongly identified as “the perpetrator of the crime in the underlying case.”

Accordingly, the Court reversed the order denying the 278A motion and remanded to the superior court for further proceedings consistent with its opinion. See: Commonwealth v. Williams, 119 N.E.3d 1171 (Mass. 2019). 

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