Commonwealth v. Camacho
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In this postconviction action arising from the misconduct of chemist Annie Dookhan at the William A. Hinton State Laboratory Institute the Supreme Judicial Court affirmed the order of the postconviction court denying Defendant postconviction relief, holding that Defendants who withdrew their guilty pleas after Dookhan's misconduct was discovered but before the Court's decision in Bridgman v. District Attorney for the Suffolk District, 471 Mass. 465 (2015), are entitled retroactively to the protection of the Bridgeman sentencing cap but only if they actually were convicted of more serious charges or received a more severe sentence than at their first plea.
Defendant successfully moved to withdraw his guilty plea to trafficking cocaine on the ground that Dookhan's misconduct rendered his plea involuntary. Defendant then pleaded guilty to possession with intent to distribute. After Bridgeman was decided Defendant moved to withdraw his second guilty plea. The motion was denied. The Supreme Judicial Court affirmed, holding that where Defendant negotiated his second plea agreement in the shadow of the original charges but was not convicted of more severe charges and did not receive a harsher punishment there was no violation of the principles underlying the Bridgeman sentencing cap and thus no need for a third plea or trial in order to apply Bridgeman retroactively.
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