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Commonwealth v. Garvey
Commonwealth v. James Garvey
Supreme Judicial Court, May 9, 2017
(Habitual Offender Statute/Grand Jury)
G.L. c. 279, 25(a) requires the underlying criminal convictions (with qualifying sentences) arise from separate incidents or episodes of criminal behavior.
Note: During presentment, the prosecutor must submit evidence to the grand jury that the defendant’s prior convictions stemmed from separate criminal events.