Commonwealth v. Claudio
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In this case involving a consequence of the evidence tampering by Sonja Farak, a chemist at the State Laboratory Institute at the University of Massachusetts at Amherst, the Supreme Judicial Court held that a defendant who qualified for an enhanced sentence due to a subsequently vacated predicate offense that had been tainted by Farak's misconduct may challenge the guilty plea without being exposed to a harsher sentence than that which he received in exchange for his plea.
Defendant was indicted on two counts alleging aggravated statutory rape and as a habitual criminal, with two drug offenses on his prior record as the predicate convictions. Defendant pleaded guilty to lesser charges without the habitual offender enhancements. Defendant was later identified as a "Farak defendant," and one of his prior drug convictions was vacated. Before seeking to withdraw his guilty plea, Defendant requested a ruling that if he succeeded in withdrawing his plea he would not be subject to a harsher punishment as the result of a reprosecution of the rape charges. The superior court judge asked whether protections from harsher punishment established for "Dookhan defendants" apply to "Farak defendants" challenging Farak-related predicate offenses that resulted in enhanced sentences on subsequent convictions. The Supreme Judicial Court answered the question in the positive.
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