Massachusetts Supreme Judicial Court Clarifies Scope of Erroneous Convictions Statute

The Massachusetts Supreme Judicial Court today ruled that a man who was convicted and sentenced to jail for illegally carrying a knife is not entitled to compensation under the Erroneous Convictions Statute, despite having had his conviction reversed by the Appeals Court.  The name of the case is Peterson v. Commonwealth.

The plaintiff found himself as a defendant in a criminal courtroom after the car he was driving was stopped by a police officer.  The area where the plaintiff had been driving was known for gang activity, and the plaintiff allegedly committed several traffic violations prior to the stop.  The cops approached the plaintiff and requested his license and registration.  The plaintiff immediately produced both, and the cops were quickly able to determine they were valid.  Nevertheless, the cops ordered the plaintiff to get out of his car.  As the plaintiff exited, the officers observed a knife that was clipped to his pants.  The police arrested the plaintiff and charged him with carrying a dangerous weapon.

In the trial court, the plaintiff filed a motion to suppress the knife, arguing the police lacked constitutional authority to order him to exit the vehicle.  Typically, a cop can order a driver to get out of his car during a traffic stop only when: (1) the cop reasonably fears for his safety; or (2) the cop reasonably believes an occupant of the car is committing a crime.  The trial judge denied the plaintiff’s motion to suppress and he was thereafter convicted by a jury of carrying a dangerous weapon.  The plaintiff was sentenced to serve two and a half years in jail.  He appealed, arguing that his motion to suppress should have been allowed and, in any event, the evidence did not establish that the knife constituted a “dangerous weapon” under Massachusetts law.  The Appeals Court agreed with the plaintiff that his motion to suppress should have been allowed by the trial judge.  Because the conviction was reversed on that ground, the Appeals Court did not decide whether the knife qualified as a dangerous weapon.

The plaintiff then filed a complaint in superior court to receive compensation under the Erroneous Convictions Statute.  The Commonwealth moved to dismiss the case and the Supreme Judicial Court agreed the plaintiff does not qualify for compensation pursuant to the statute.  The law allows individuals who have been erroneously convicted of felonies and sent to jail to sue the Commonwealth for monetary damages.  However, the statute only applies to cases where an appeals court has determined the conviction should be reversed on grounds that tend to establish the innocence of the plaintiff.  In other words, it’s not enough that the plaintiff’s conviction was reversed on procedural grounds (such as an unconstitutional police search).  The plaintiff must establish evidence that he was actually innocent.

In this case, the SJC concluded the plaintiff’s conviction was not reversed on grounds that tend to prove he did not commit the crime.  It was reversed only because the cops committed misconduct.  The SJC said it was not in a position to determine if the plaintiff’s knife was illegal.  Accordingly, because the plaintiff’s conviction was reversed on procedural grounds, he is out of luck.

In a thoughtful concurrence, Chief Justice Gants pointed out that by declining to address the plaintiff’s contention that his knife was not illegal, the Appeals Court denied him the opportunity to seek the compensation to which he was owed under the statute.  The chief justice suggested an appellate court ought to consider appellants’ challenges to the sufficiency of the evidence before considering other claimed errors.