Decision Commonwealth v. Williams; Commonwealth v. Putnam

Date: 04/09/2019
Organization: Massachusetts Supreme Judicial Court

Commonwealth v. Williams
Commonwealth v. Putnam
Supreme Judicial Court, April 9, 2019

(Post-Conviction Relief/Forensic Testing)


G. L. c. 278A allows those who have been convicted but assert factual innocence to have access to forensic and scientific testing of evidence and biological material that has the potential to prove their innocence.


The Court held that “a defendant who asserts that the requested testing has the potential to result in evidence that is material to his or her identity as the perpetrator of the crime because no crime in fact occurred satisfies the § 3 (b) (4) requirement.”


In Commonwealth v. Williams the Court agreed with the defendant that under G.L. c. 278A, he may assert factual innocence of manslaughter because he was convicted based on acts taken in self-defense.

“[A] claim of self-defense is a claim that the homicide was justified and, here, for purposes of chapter 278A, it is a claim that the movant is factually innocent of manslaughter.”


In Commonwealth v. Putnam the Court found that the defendant’s motion satisfies the threshold burden of § (3) (b) (4) when he asserted his factual innocence claiming that he was not guilty of home invasion because he did not enter the victim's home with the intent to commit a crime; that he was not guilty of armed assault or assault and battery because he did not use force on, nor caused injury to, the victim; and that he was not guilty of rape because he did not penetrate the victim.

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