James Bing, Jr. v. Department of Correction.

CourtMassachusetts Appeals Court
DecidedMay 1, 2025
Docket24-P-0362
StatusUnpublished

This text of James Bing, Jr. v. Department of Correction. (James Bing, Jr. v. Department of Correction.) is published on Counsel Stack Legal Research, covering Massachusetts Appeals Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
James Bing, Jr. v. Department of Correction., (Mass. Ct. App. 2025).

Opinion

NOTICE: Summary decisions issued by the Appeals Court pursuant to M.A.C. Rule 23.0, as appearing in 97 Mass. App. Ct. 1017 (2020) (formerly known as rule 1:28, as amended by 73 Mass. App. Ct. 1001 [2009]), are primarily directed to the parties and, therefore, may not fully address the facts of the case or the panel's decisional rationale. Moreover, such decisions are not circulated to the entire court and, therefore, represent only the views of the panel that decided the case. A summary decision pursuant to rule 23.0 or rule 1:28 issued after February 25, 2008, may be cited for its persuasive value but, because of the limitations noted above, not as binding precedent. See Chace v. Curran, 71 Mass. App. Ct. 258, 260 n.4 (2008).

COMMONWEALTH OF MASSACHUSETTS

APPEALS COURT

24-P-362

JAMES BING, JR.

vs.

DEPARTMENT OF CORRECTION.

MEMORANDUM AND ORDER PURSUANT TO RULE 23.0

The plaintiff, James Bing, Jr., challenged an adverse

finding of a disciplinary board by filing an action pursuant to

G. L. c. 249, § 4. After a hearing, a judge of the Superior

Court issued an order denying Bing's motion for judgment on the

pleadings and allowing the cross motion of the defendant,

Department of Correction (department). Bing appeals from the

judgment. We affirm.

Discussion. The following facts are undisputed. In

February 2022, during a search of Bing's prison cell, correction

officers found a piece of paper that reportedly had an "odd

texture." The correction officers, suspecting that the paper

contained an unauthorized substance, placed the paper into evidence and sent it to the University of Massachusetts Medical

School Drugs of Abuse Laboratory (laboratory). On April 15,

2022, the laboratory certified that "[s]creening test(s)" showed

that the paper tested positive for synthetic cannabinoid, and

the results were notarized. On May 13, 2022, following receipt

of the positive test result, a correction officer wrote a

disciplinary report charging Bing with unauthorized use or

possession of drugs, in violation of 103 Code Mass. Regs.

§ 430.24(2-11) (2019), and two other offenses. After a

disciplinary hearing, the hearing officer found sufficient

evidence to support a guilty finding as to the charge of

unauthorized use or possession of drugs, and dismissed the other

charges.

"Our review of a disciplinary proceeding is based on

whether the record contains substantial evidence to support the

hearing officer's decision" (citation omitted). Shea v.

Department of Correction, 103 Mass. App. Ct. 369, 372 (2023).

"Substantial evidence is evidence that a reasonable mind might

accept as adequate to support a conclusion, . . . taking into

account whatever in the record fairly detracts from the weight

of the evidence" (quotation and citation omitted). Id. "The

court may not displace the hearing officer's exclusive function

to weigh the credibility of the witnesses and to resolve factual

disputes in the testimony" (quotation and citation omitted).

2 Id. at 372-373. "We may correct only a substantial error of

law, evidenced by the record, which adversely affects a material

right of the plaintiff" (quotation and citation omitted).

Winthrop Retirement Bd. v. LaMonica, 98 Mass. App. Ct. 360, 366

(2020).

Bing contends that the evidence on which the hearing

officer relied was insufficient to support a guilty finding

because the forensic test of the paper was a "screening" test

and not a "confirmation" test. The department's substance abuse

identification and testing policies state that qualified staff

"shall screen [unknown, unauthorized substances] using a

narcotic field test kit in an attempt to identify the

substance." 103 DOC § 525.08 (2021). If the quantity of the

unknown substance is limited, however, it "shall not be field

tested, but may be sent out for identification via a laboratory

test." 103 DOC § 525.08(B)(2). Also, if a substance cannot be

identified by field testing, it "may be sent to an outside

laboratory for testing and identification." 103 DOC

§ 525.08(C)(1). On the other hand, if an unknown substance is

identified by field testing and there is reason to believe that

an inmate has committed a disciplinary offense, the inmate must

be served with a form giving him the option to request a

"[c]onfirmation [t]est." 103 DOC § 525.08(C)(2). The policy

definitions contemplate the screening test is to be performed by

3 department staff. 103 DOC § 525.01 (2021). Similarly, the

department has written its own definition of a "[c]onfirmation

[t]est," defining it as "[a] forensic test conducted by a

certified laboratory to detect the presence of unauthorized

drugs."1 Id. The definition of [c]onfirmation [t]est concludes,

"The results of a laboratory test shall always override the

results of any screening results obtained by [d]epartment

staff." Id.

Here, the department effectively skipped "step one," field

testing, by sending the substance directly to the laboratory for

testing. As noted, the department's policy authorizes this

action. Thus, to the extent Bing is arguing that the department

failed to comply with its policy, we disagree. The policy

allows the department to send an unknown substance to an outside

laboratory for identification without first conducting a field

test. Thus, we discern no error in this regard that adversely

affected Bing's rights. See Winthrop Retirement Bd., 98 Mass.

App. Ct. at 366.

1 The department's definitions of a "screening" test and a "confirmation" test are not consistent with how a scientist from an independent certified laboratory would use those terms. While the department may define terms in its regulations, the department should expect that deviating from well-known definitions will cause unnecessary confusion and invite litigation. The department compounds the confusion by using the phrase "field testing" interchangeably with "screening."

4 The question then is whether the results from the

laboratory, in combination with the other evidence before the

hearing officer, constituted substantial evidence supporting the

hearing officer's decision. The substantial evidence standard

is highly deferential to the agency decision maker and is less

stringent than preponderance of the evidence. See Duggan v.

Board of Registration in Nursing, 456 Mass. 666, 674 (2010).

Under the substantial evidence standard, "an agency's conclusion

will fail judicial scrutiny if the evidence points to no felt or

appreciable probability of the conclusion or points to an

overwhelming probability of the contrary" (quotation and

citation omitted). Id. That is not the case here. Rather, the

hearing officer's decision was supported by substantial

evidence, as the finding that Bing possessed an unauthorized

substance was supported by the testing of an outside laboratory.

We are unpersuaded by Bing's suggestions that substantial

evidence is lacking because screening tests, such as those used

by the department, are presumptively unreliable. Although the

laboratory used the term "screening," that did not transform the

laboratory's test into a screening test within the meaning of

the department's policy.2 "Screening," as used in the policy,

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Related

Duggan v. Board of Registration in Nursing
925 N.E.2d 812 (Massachusetts Supreme Judicial Court, 2010)
Chace v. Curran
881 N.E.2d 792 (Massachusetts Appeals Court, 2008)

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