Commonwealth v. Francis
Annotate this CaseAfter a trial, Defendant was found guilty of the trafficking and distribution of cocaine. During trial, drug certificates were admitted into evidence that were signed by Annie Dookhan declaring that the substances in question were cocaine and that set forth their weight. Six years after the jury returned their guilty verdicts, Defendant filed a motion for a new trial, alleging that he was entitled to a new trial because of newly discovered evidence arising from Dookhan’s misconduct in conducting drug analyses. The trial judge denied the motion. The Appellate Court affirmed. The Supreme Judicial Court vacated Defendant’s convictions and remanded for a new trial, holding (1) a defendant found guilty at trial who moves for a new trial is entitled to the same conclusive presumption of “egregious government misconduct” that the Court applied in Commonwealth v. Scott to cases where a defendant seeks to withdraw his guilty plea after learning of Dookhan’s misconduct; and (2) the trial court in this case erred in admitting the drug certificates regarding Dookhan’s drug analysis, and the Commonwealth did not meet its burden of proving that the admission of the drug certificates did not influence the jury or had only a slight effect on their verdicts.
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