Renaud v. Commonwealth

12 Citing cases

  1. Santana v. Commonwealth

    88 Mass. App. Ct. 553 (Mass. App. Ct. 2015)   Cited 4 times
    Affirming order denying Commonwealth's motion for reconsideration in wrongful conviction case in which judgments regarding possession of narcotics found in car in which plaintiff was a passenger were reversed based on insufficiency of evidence

    Although the memorandum was issued without the benefit of Renaud v. Commonwealth, 471 Mass. 315, 28 N.E.3d 478 (2015), discussed infra, the reasoning of the motion judge closely followed that of Renaud. The notice of appeal mentions only the motion for reconsideration, and does not contain any language that the Commonwealth is appealing from the original order.

  2. Peterson v. Commonwealth

    478 Mass. 434 (Mass. 2017)   Cited 7 times

    "[T]he eligibility requirement is ‘separate and distinct from the merits of the claim of relief that a claimant must establish at trial,’ namely that he or she did not commit the charged offense." Renaud v. Commonwealth, 471 Mass. 315, 319, 28 N.E.3d 478 (2015), quoting Irwin, 465 Mass. at 842, 992 N.E.2d 275. At trial, the burden on individuals eligible to seek relief under the erroneous convictions statute is much greater: they bear the burden of establishing by "clear and convincing evidence" that they did not commit the crimes with which they were charged. G. L. c. 258D, § 1 (C)."We have cautioned, however, that such grounds must ‘tend[ ] to do more than merely assist the defendant's chances of acquittal.

  3. Santana v. Commonwealth

    90 Mass. App. Ct. 372 (Mass. App. Ct. 2016)   Cited 4 times
    Holding that a reversal due to an improper jury instruction on a lesser included offense was not a reversal for reasons that tended to establish innocence

    “[T]he eligibility requirement is ‘separate and distinct from the merits of the claim of relief that a claimant must establish at trial,’ namely that he or she did not commit the charged offense.” Renaud v. Commonwealth, 471 Mass. 315, 319, 28 N.E.3d 478 (2015), quoting from Irwin v. Commonwealth, 465 Mass. 834, 839, 842, 992 N.E.2d 275 (2013). See also Guzman II, supra at 360–361, 937 N.E.2d 441 (“we do not discern a legislative intent that the determination of eligibility be tantamount to a testing of the merits of a claimant's case”).

  4. Peterson v. Commonwealth

    SJC-12281 (Mass. Nov. 29, 2017)

    "[T]he eligibility requirement is 'separate and distinct from the merits of the claim of relief that a claimant must establish at trial,' namely that he or she did not commit the charged offense." Renaud v. Commonwealth, 471 Mass. 315, 319 (2015), quoting Irwin, 465 Mass. at 842. At trial, the burden on individuals eligible to seek relief under the erroneous convictions statute is much greater: they bear the burden of establishing by "clear and convincing evidence" that they did not commit the crimes with which they were charged. G. L. c. 258D, § 1 (C).

  5. Cruz v. Commonwealth

    102 Mass. App. Ct. 685 (Mass. App. Ct. 2023)   Cited 1 times

    Previous appellate cases that have analyzed the eligibility requirement of G. L. c. 258D have not addressed the incorporation of § 1 (C) (vi) into § 1 (B) (ii). See, e.g., Renaud v. Commonwealth, 471 Mass. 315, 318, 28 N.E.3d 478 (2015) ; Irwin, 465 Mass. at 839, 992 N.E.2d 275 ; Guzman, 458 Mass. at 356, 937 N.E.2d 441. At oral argument, both parties agreed that there were no appellate cases on the precise question presented here, and we have found none.

  6. Fragata v. Commonwealth

    99 Mass. App. Ct. 1127 (Mass. App. Ct. 2021)

    The reversal of Fragata's conviction on this basis was not " ‘on grounds which tend to establish ... innocence’ under G. L. c. 258D, § 1 (B ) (ii)." Renaud v. Commonwealth, 471 Mass. 315, 319 (2015). See Santana v. Commonwealth, 90 Mass. App. Ct. 372, 375-376 (2016) (where it was unclear on what theory of guilt the jury relied in convicting defendant, reversal of conviction due to erroneous jury instructions did not tend to establish defendant's innocence).

  7. Kneer v. Zoning Bd. of Appeals of Norfolk

    93 Mass. App. Ct. 548 (Mass. App. Ct. 2018)   Cited 2 times

    Of course, the Supreme Judicial Court is free to adopt our reasoning by reference. See, e.g., Renaud v. Commonwealth, 471 Mass. 315, 319 n.6, 28 N.E.3d 478 (2015) ; Commonwealth v. Brown, 479 Mass. 600, 607, 97 N.E.3d 349 (2018). In addition, when a case taken on further appellate review ends in a tie vote in the Supreme Judicial Court, the Appeals Court opinion is resurrected "unless a majority of the participating justices [of the Supreme Judicial Court] decides otherwise."

  8. Cruz v. Commonwealth

    No. SJC-13503 (Mass. Oct. 16, 2024)

    See also Renaudv.Commonwealth, 471 Mass. 315, 317 (2015) ("The erroneous convictions statute was enacted to ensure that 'those erroneously convicted but factually innocent be afforded equal opportunities to obtain compensation'" [citation omitted]).

  9. Knight v. Attorney Gen.

    No. 22-P-765 (Mass. App. Ct. Apr. 10, 2024)

    Irwin v. Commonwealth, 465 Mass. 834, 846 (2013), quoting Guzman, 458 Mass. at 358. Because the plaintiff's convictions were not vacated on grounds tending to establish innocence, he is not eligible for relief under G. L. c. 258D. Contrast Renaud v. Commonwealth, 471 Mass. 315, 319 (2015) (grounds for relief pertained to insufficient evidence of "the identity of the defendant"); Drumgold v. Commonwealth, 458 Mass. 367, 378 (2010) (grounds for relief probative of "reliability of the identification of [the defendant] as one of the shooters"); Guzman, 458 Mass. at 365 (grounds for judicial relief tend to establish innocence where "erroneously omitted evidence was probative of the conclusion that the culprit was someone else"). Finally, based on the result we have reached, we need not consider whether the length of the plaintiff's sentences qualified for relief under G. L. c. 258D.

  10. In re Bozzo

    C. A. PM-2022-3883 (R.I. Super. Jun. 8, 2023)   Cited 2 times

    Id. at *4; accord Renaud v. Commonwealth, 28 N.E.3d 478, 481 (Mass. 2015) ("[T]he eligibility requirement is 'separate and distinct from the merits of the claim of relief that a claimant must establish at trial,' namely that he or she did not commit the charged offense.") (quoting Irwin v. Commonwealth, 992 N.E.2d 275, 282 (Mass. 2013)).