Renaud v. CommonwealthAnnotate this Case
After a jury-waived trial, Plaintiff was found guilty of malicious destruction of property, breaking and entering in daytime, and larceny over $250. The Appeals Court reversed Plaintiff’s convictions, concluding that the Commonwealth’s evidence was insufficient to support the convictions. Thereafter, Plaintiff filed a complaint under Mass. Gen. Laws ch. 258D, the erroneous convictions statute, seeking compensation for his erroneous convictions. The Commonwealth filed a motion to dismiss Plaintiff’s complaint, arguing that Plaintiff did not meet his threshold burden of proving that his convictions were overturned “on grounds which tend to establish [his] innocence” under the erroneous convictions statute. A judge denied the motion. The Commonwealth appealed. The Supreme Judicial Court affirmed the denial of the motion to dismiss, holding that the reversal of Plaintiff’s convictions due to insufficient evidence amounted to grounds which tend to establish Plaintiff’s innocence, thus rendering Plaintiff eligible to obtain relief under the erroneous convictions statute.