Graham v. District Attorney for the Hampden DistrictAnnotate this Case
In this case, six plaintiffs -- two criminal defense organizations, two defense attorneys, and two former criminal defendants -- filed a petition against the District Attorney's Office for the Hampden District in Massachusetts. The plaintiffs alleged multiple failures by the District Attorney's Office, primarily stemming from its handling of evidence of misconduct within the Springfield Police Department (the department). The U.S. Department of Justice had previously conducted an investigation and found that officers in the department, particularly those within the narcotics bureau, routinely falsified police reports and engaged in a pattern of excessive force.
The Supreme Judicial Court of Massachusetts found that the District Attorney's Office, through certain discovery policies, committed a breach of both the duty to disclose evidence that tends to exculpate defendants and the duty to investigate or inquire about such evidence. Specifically, the court identified three problematic practices: 1) disclosing adverse credibility findings made about the department's officers only on a discretionary basis; 2) withholding instances of officer misconduct from disclosure where a specific bad act cannot be clearly attributed to a particular officer; and 3) failing to gain access to all documents known to have been reviewed by the Department of Justice (DOJ).
To rectify these breaches, the court ordered the District Attorney's Office to obtain access to all categories of documents known to have been reviewed by the DOJ and disclose them to the plaintiffs. From there, case-by-case adjudication can begin to address the claims of individual defendants affected by the department's misconduct. In issuing this order, the court emphasized the importance of a prosecutor's dual duties -- to disclose and to investigate -- in upholding the integrity of the criminal justice system.