Commonwealth v. Roberts
Annotate this CaseDefendant pleaded guilty to several sexual offenses, including forcible rape, committed against three children. Neither Defendant’s defense counsel nor the judge who accepted his guilty pleas informed Defendant that his sexual offenses could serve as a predicate for civil confinement as a sexually dangerous person for life. A judge in the superior court allowed Defendant’s motion to withdraw his guilty pleas on the ground that the failure of the plea judge to inform Defendant of possible civil commitment violated due process and Mass. R. Crim. P. 12(c)(3)(B). The Supreme Judicial Court vacated the order allowing Defendant to withdraw his guilty pleas and remanded, holding (1) the judge’s analogy to Padilla v. Kentucky was inapt in this case; and (2) the defendant may withdraw his guilty plea if he can establish a reasonable probability that he would not have pleaded guilty had the judge informed him of the possibility of future civil confinement as required by Rule 12. Remanded for further findings and rulings applicable to the correct legal standard.
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