Commonwealth v. Carlos Ramon Zapata

CourtMassachusetts Superior Court
DecidedJuly 10, 2020
Docket1877CR00618
StatusPublished

This text of Commonwealth v. Carlos Ramon Zapata (Commonwealth v. Carlos Ramon Zapata) is published on Counsel Stack Legal Research, covering Massachusetts Superior Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Commonwealth v. Carlos Ramon Zapata, (Mass. Ct. App. 2020).

Opinion

SUPERIOR COURT

COMMONWEALTH vs. CARLOS RAMON ZAPATA

Docket: 1877CR00618
Dates: August 21, 2019
Present: Jeffrey T. Karp Associate Justice, Superior Court
County: ESSEX, ss.
Keywords: MEMORANDUM OF DECISION AND ORDER ON DEFENDANT'S MOTION FOR RELEASE ON BAIL (Paper No. 20)

            Defendant Carlos Ramon Zapata ("Zapata") is charged with armed burglary, aggravated rape, and other crimes arising from an incident on September 1, 1999. The trial of this matter is scheduled to commence on October 28, 2019.

            Zapata was arraigned in this matter on October 16, 2018. On that date, the Commonwealth moved for pretrial detention pursuant to G.L. c. 276, § 58A ("section 58A"). (See Paper No. 5). A hearing on that motion was conducted on November 5, 2018, before the Court, Drechsler, J., presiding. The Court allowed the motion for pretrial detention on November 7, 2018. (See endorsement on Paper No. 5 and Findings And Order On Motion For Detention Under G.L. c. 276, § 58A). Consequently, Zapata is held without bail pursuant to section 58A.

            On August 6, 2019, the Court conducted a hearing on Defendant's Motion For Release On Bail (Paper No. 20). In support of his motion, Zapata argues that he is entitled to be admitted to bail at a bail hearing because he has been detained without bail for a period of time exceeding the maximum period of detention of 180 days authorized by section 58A(3). As is explained below, section 58(3) excludes from the maximum period of detention certain events that are excludable under Mass.R.Crim.P.

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36(b)(2). This Court's review of the docket and the Commonwealth's submission[1] reveals that the entirety of the delay is excluded from the 180 day maximum period of detention because Zapata acquiesced to, or was responsible for, the delay. Therefore, after thorough consideration of the submissions, the procedural history, and arguments of counsel, the motion is DENIED.

STATUTORY OVERVIEW

            Section 58A establishes a presumptive deadline by which a defendant that has been detained without bail on a finding of dangerousness must be brought to trial. The statute provides in relevant part as follows:

A person detained under this subsection shall be brought to a trial as soon as reasonably possible, but in absence of good cause, the person so held shall not be detained . . . for a period exceeding 180 days by the superior court excluding any period of delay as defined in Massachusetts Rules of Criminal Procedure Rule 36(b)(2).

G.L. c. 276, § 58A(3) (emphasis added).[2]

            In the context of a speedy trial challenge under Rule 36, when a "defendant establishe[s] a prima facie violation of the rule, . . . [t]he burden shifts to the Commonwealth to justify the delay." Commonwealth v. Roman, 470 Mass. 85, 92 — 93 (2014) (citations omitted); see also Commonwealth v. Denehy, 466 Mass. 723, 729 (2014) (same). Because § 58A implicates fundamental liberty interests, the burden is on

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[1] The Commonwealth filed a memorandum in opposition that contains a schedule setting forth the dates of events in this action and its view of whether the time between the dates is excludable or includable under Rule 36. Zapata filed no such schedule and stated at the hearing that he relies on the Court's review of the docket.

[2] Section 58A was enacted in 1994 and, although the period of detention has been amended (lengthened) a few times, the maximum period of detention in Section 58(A)(3) has always "exclude[ed] any period of delay as defined in Massachusetts Rules of Criminal Procedure Rule 36(b)(2)."

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the Commonwealth to demonstrate the proper exclusion of time if a defendant makes a prima facie showing that he has been detained for more than 180 days.

            Rule 36(b)(2), in turn, specifies a number of temporal circumstances that "shall be excluded in computing the time within which the trial of any offense must commence." Among these are "delay resulting from hearings on pretrial motions," Mass.R.Crim.P. 36(b)(2)(A)(v); and, "delay reasonably attributable to any period, not to exceed thirty days, during which any proceeding concerning the defendant is actually under advisement." Mass.R.Crim.P. 36(b)(2)(A)(vii). "Also excludable is `[a]ny period of delay resulting from a continuance granted by a judge . . . , if the judge granted the continuance on the basis of his findings that the ends of justice served by taking such action outweighed the best interests of the public and the defendant in a speedy trial.'" Commonwealth v. Dirico, 480 Mass. 491, 498 (2018) (quoting Mass.R.Crim.P. 36(b)(2)(F)).

PROCEDURAL HISTORY

            Given the application of Rule 36, the Court will set forth the procedural history of this case in some detail.

            Zapata was arraigned on October 16, 2018, and the matter was continued to November 5, 2018, for a hearing on the section 58A motion. The record is silent regarding the identity of the party requesting the continuance.[3] However, by failing to

[3] According section 58A:

The hearing shall be held immediately upon the person's first appearance before the court unless that person, or the attorney for the commonwealth, seeks a continuance. Except for good cause, a continuance on motion of the person may not exceed seven days, and a continuance on motion of the attorney for the commonwealth may not exceed three business days.

G.L. c. 276, § 58A(4). Thus, given that the continuance exceeded seven days, the Court is presumed to have found "good cause" for the continuance.

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object to the continuance, Zapata acquiesced to the 20 days that passed between the arraignment and the November 5 hearing.[4] Dirico, 480 Mass. at 499 (quoting Barry v.  Commonwealth, 390 Mass. 285, 298 (1983) ("A defendant is held to have acquiesced in a delay if he or she 'agreed to a continuance ... or has not entered an objection to delay.").

            The section 58A hearing was conducted on November 5, 2018, and the matter was continued to December 18, 2018, for a motion hearing. The record is silent regarding the identity of the party requesting the continuance. The Court took the section 58A motion under advisement and issued the detention order on November 7, 2018. Thus, including the first and last day of the excludable event (see note 4, supra) the 3 days between the hearing and the decision are excluded under Rule 36(b)(2)(A)(vii).

[4] "In making [the] calculations, [the Court] adhere[s] to rule 36 (b) (3), which provides: 'In computing any time limit other than an excluded period, the day of the act or event which causes a designated period of time to begin to run shall not be included. Computation of an excluded period shall include both the first and the last day of the excludable act or event.' However, IV there are excludable periods of delay which overlap, a day is excluded only once." Commonwealth v. Dirico, 480 Mass. 491, 497 n.5 (2018) (quoting Barry v. Commonwealth, 390 Mass. 285, 292 (1983)).

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Commonwealth v. Carlos Ramon Zapata, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-carlos-ramon-zapata-masssuperct-2020.