Commonwealth v. Hastings

CourtMassachusetts Supreme Judicial Court
DecidedMay 13, 2024
DocketSJC 13495
StatusPublished

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

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Commonwealth v. Hastings, (Mass. 2024).

Opinion

NOTICE: All slip opinions and orders are subject to formal revision and are superseded by the advance sheets and bound volumes of the Official Reports. If you find a typographical error or other formal error, please notify the Reporter of Decisions, Supreme Judicial Court, John Adams Courthouse, 1 Pemberton Square, Suite 2500, Boston, MA, 02108-1750; (617) 557- 1030; SJCReporter@sjc.state.ma.us

SJC-13495

COMMONWEALTH vs. QUASIM HASTINGS & another.1

Berkshire. January 8, 2024. – May 13, 2024.

Present: Budd, C.J., Gaziano, Kafker, Wendlandt, & Georges, JJ.

Indigent. Parole. Imprisonment, Parole, Disabled prisoner. Constitutional Law, Parole. Practice, Criminal, Parole. Statute, Construction. Mental Health. Social Worker.

Indictment found and returned in the Superior Court Department on May 14, 2003.

An ex parte motion for funds to retain an expert, filed on August 12, 2022, was considered by Douglas H. Wilkins, J.; a motion for reconsideration was heard by him; and the case was reported by him to the Appeals Court.

The Supreme Judicial Court granted an application for direct appellate review.

Sharon Dehmand for the defendant. Andre A. Janiszewski, Assistant Attorney General, for the intervener. Benjamin H. Keehn, Committee for Public Counsel Services, for Committee for Public Counsel Services, amicus curiae, submitted a brief.

1 Massachusetts Parole Board, intervener. 2

GAZIANO, J. This appeal concerns the scope of the

constitutionally mandated exception to G. L. c. 261, §§ 27A-27G

(indigency statute), carved out in Diatchenko v. District

Attorney for the Suffolk Dist., 471 Mass. 12, 26-27 (2015)

(Diatchenko II). In particular, we address whether the

exception authorizes a judge to allow an indigent prisoner's

motion for funds to retain an expert witness for an upcoming

parole hearing.

Quasim Hastings, convicted of murder in the second degree

in 2004, is eligible to be considered for release on parole. He

has been diagnosed with a mental disability and, therefore, is

entitled to a parole hearing that affords him protections

secured by art. 114 of the Amendments to the Massachusetts

Constitution as well as Federal and State statutes prohibiting

discrimination on the basis of disability. See Crowell v.

Massachusetts Parole Bd., 477 Mass. 106, 110-112 (2017).

Prior to a 2023 parole hearing, appointed counsel for

Hastings filed, in the original criminal case, a motion for

funds to retain a forensic psychologist under Crowell. A

Superior Court judge allowed the motion.

Hastings's counsel filed a second motion for funds to

retain a social services advocate to assist with preparing a

prerelease plan. A different Superior Court judge denied this

request for public funds. The judge reasoned that the plain 3

language of the indigency statute limits his authority to

approve funds to pending proceedings or appeals in any court.

He found also that this court's constitutionally mandated

exception does not extend to Hastings's statutory right to

parole consideration. The judge reported to the Appeals Court

his denial of the motion for funds, and we granted Hastings's

application for direct appellate review.

For the following reasons, we conclude that Hastings's

motion for funds to retain a social services advocate implicates

his State constitutional right to reasonable disability

accommodations. Because the constitutionally mandated exception

to the indigency statute applies, the order denying Hastings's

motion for funds is reversed.2

Background. In 2004, Hastings pleaded guilty in the

Superior Court to murder in the second degree and was sentenced

to life with the possibility of parole in fifteen years. See

G. L. c. 265, § 2; G. L. c. 127, § 133A. Hastings, in 2015, was

diagnosed with mental illnesses, including major depressive

disorder with psychotic features. Prior to Hastings's initial

2019 parole hearing, the Massachusetts Parole Board (board)

2 We acknowledge the amicus brief submitted by the Committee for Public Counsel Services in support of Hastings and the amicus letter submitted by the Committee for Public Counsel Services and Prisoners' Legal Services of Massachusetts. 4

requested an appointment of counsel from the Committee for

Public Counsel Services (CPCS) based on Hastings's mental health

disability. CPCS assigned Hastings counsel. In 2018,

Hastings's counsel filed in his Superior Court criminal case a

motion for funds to retain the services of a forensic

psychiatrist to assist in the parole hearing. See Commonwealth

vs. Hastings, Mass. Super. Ct., No. 0376CR00106 (Berkshire

County May 14, 2003). A Superior Court judge allowed the

motion. The board denied Hastings's petition for parole in

2019, and he was given a four-year setback. See Roberio v.

Massachusetts Parole Bd., 483 Mass. 429, 432 (2019) (period

between board's denial of parole and prisoner's statutory right

to subsequent review is referred to as "setback").

Hastings's counsel, in advance of the 2023 parole hearing,

filed two additional motions for funds in Hastings's Superior

Court criminal case. In the first motion, filed on June 6,

2022, $5,000 was requested to retain a forensic psychologist.

Counsel represented that "[a]n updated evaluation and testimony

by a forensic psychologist are necessary for . . . Hastings to

adequately present his case for parole." A Superior Court judge

allowed the motion on June 10, 2022.

Next, on August 12, 2022, Hastings's counsel filed a motion

for funds to retain a social services advocate to assist with

preparing a release plan. According to counsel, "[p]art of 5

. . . Hastings'[s] application for parole will involve having an

extensive release plan which requires application and acceptance

by the Department of Mental Health as well as placement,

housing, and other mental health services." A different

Superior Court judge (motion judge), on September 22, 2022,

denied the motion for funds as exceeding the Superior Court's

statutory authority. He explained, "The [c]ourt's authority

under G. L. c. 261, [§ 27B,] is limited to 'any civil, criminal

or juvenile proceeding or . . . appeal in any court.' A parole

hearing is not 'in any court.'"

Hastings's counsel, on October 19, 2022, moved for

reconsideration. The motion was supported by affidavits of a

social worker and the director of the CPCS parole advocacy unit.

The social worker noted that "[c]lients with disabilities often

require experts specialized in services for people with

disabilities." She explained the advantages of retaining a

clinician to identify appropriate support networks and services

to assist a client's successful reentry into the community. The

director of the CPCS parole advocacy unit noted that the board

"often relies upon expert evaluations and reports obtained by

counsel via a motion for funds in determining the suitability of

disabled prisoners for release on parole." She added that it

therefore is "imperative" for disabled parole candidates to

present comprehensive release plans crafted by social services 6

experts capable of navigating complex intra-agency referrals,

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Related

Commonwealth v. Davis
574 N.E.2d 1007 (Massachusetts Supreme Judicial Court, 1991)
Diatchenko v. District Attorney for the Suffolk District Commonwealth v. Roberio
27 N.E.3d 349 (Massachusetts Supreme Judicial Court, 2015)
Reade v. Secretary of the Commonwealth
36 N.E.3d 519 (Massachusetts Supreme Judicial Court, 2015)
Crowell v. Massachusetts Parole Board
74 N.E.3d 618 (Massachusetts Supreme Judicial Court, 2017)
Commonwealth v. Carter
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Shedlock v. Department of Correction
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Carleton v. Commonwealth
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Commonwealth v. Matranga
914 N.E.2d 17 (Massachusetts Supreme Judicial Court, 2009)
Edwards
984 N.E.2d 276 (Massachusetts Supreme Judicial Court, 2013)

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