Boston Criminal Defense Lawyer Blog
Recently, a state appellate court issued an opinion in a Massachusetts gun case, affirming the principle that “a conviction cannot stand if the defendant proves that the jury’s deliberations were infected by racial or ethnic bias.” The case involved a defendant who entered a guilty plea to a sentencing enhancement who later found out from a juror that the jury’s deliberations were “infected by racial bias.”
The Facts of the Case
According to the court’s opinion, immediately after the defendant was found guilty of possession of a firearm, one of the jurors approached defense counsel concerned about the “amount of racism vocalized during the deliberations by several of the jurors who voted to find the defendant guilty.” Defense counsel asked the court for the names and contact information of the jurors so that they could investigate the claim. The judge denied the defendant’s request, instead suggesting that the prosecutor agree to drop the more serious sentencing enhancement and proceed only with the less serious enhancement. The prosecutor agreed, at which point the defendant pled guilty to the lesser of two sentencing enhancements.
The defendant appealed his guilty plea, arguing that the judge improperly denied his motion to look into any potential racial bias in the jury. The defendant further claimed that his guilty plea regarding the sentencing enhancement was involuntary and, therefore, invalid.
The Courts Decision on Appeal
On appeal, the court agreed with the defendant, vacating his sentence, and ordered that the jurors’ names be passed to defense counsel. The court explained that racial bias in the criminal justice system is “a familiar and recurring evil that, if left unaddressed, would risk systemic injury to the administration of justice.” The court then noted that, when a defendant raises a valid issue as to whether there was impermissible racial bias in the jury deliberation process, it cannot be ignored. Thus, the court explained that the lower court was wrong to prevent the defendant from looking into the claim of racial bias.
The court went on to outline the process of such an inquiry. First, the judge must determine if any of the jurors made comments suggesting they were racially biased. If so, the next step is for the judge to determine if the statements were actually made with racial bias. However, even if the judge determines that the statements were not indicative of actual bias, the judge must determine if they “infected” the jury deliberation process nonetheless.
Here, the court did none of the above, and denied the defendant’s motion immediately. Thus, the court vacated the defendant’s sentence and ordered that the names of the jurors be provided to defense counsel.
Have You Been Charged with a Serious Massachusetts Crime?
If you have recently been charged with a serious crime in Boston or elsewhere in Massachusetts, contact Attorney Patrick J. Murphy. Attorney Murphy fights hard for his clients at every step in the process. With decades of experience handling all types of criminal cases, you can rest assured that you and your case are in good hands. Attorney Murphy handles all types of cases, including Massachusetts gun crimes, drug offenses, and more. To schedule a free consultation, call 617-367-0450 today.