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Conflicting State Statutes Require Reversal of Massachusetts Riot Convictions
Defendant Randall Spearin and co defendant Gualter M. Camara, both Massachusetts State prisoners, appealed their convictions from a 2001 uprising at the Bristol County House of Corrections (Bristol), where they were incarcerated and led a riot. When they filed an appeal, the Supreme Judicial Court of Massachusetts took jurisdiction for efficient judicial administration, as they undoubtedly would receive the case after appeal.
Because of conflicting state statutes, some convictions were reversed.
A riot occurred at Bristol, damaging a building, and a guard was injured after being taken hostage. Spearin, Camara and other prisoners refused to disburse. A jury convicted Spearin and Camara, as joint venturers, of building destruction while unlawfully assembled, causing injury to a penal institution, and refusal to disburse from an unlawful assembly. Camara was also convicted of assault on a guard, assault by means of a dangerous weapon and hostage taking. The prisoners appealed.
Spearin claimed that the statute he was convicted under didn't apply to county house of correction disruptions, and Camara claimed that the trial court erred in excluding evidence and in jury instruction, as a prior fight between the two prisoners precluded them being joint venturers.
The Court held that while Mass. Gen. Laws ch. 269 §§ 1 and 7 provide for criminal penalties for riotous conduct damaging property, §§ 2, 3, 4, 5, 6 and 8 conflicted by omitting riots at prisons. The Court further held the statutory sections must be read in conjunction, finding that the conflict warranted reversal of all convictions except the convictions for causing injury to a penal institution.
Camara's conviction of hostage taking was upheld, as the trial court did not error. The convictions that were affirmed were ones filed with both prisoners' consent at trial. See: Commonwealth v. Spearin, 446 Mass. 599, 846 N.E.2d 390 (2006).
Because of conflicting state statutes, some convictions were reversed.
A riot occurred at Bristol, damaging a building, and a guard was injured after being taken hostage. Spearin, Camara and other prisoners refused to disburse. A jury convicted Spearin and Camara, as joint venturers, of building destruction while unlawfully assembled, causing injury to a penal institution, and refusal to disburse from an unlawful assembly. Camara was also convicted of assault on a guard, assault by means of a dangerous weapon and hostage taking. The prisoners appealed.
Spearin claimed that the statute he was convicted under didn't apply to county house of correction disruptions, and Camara claimed that the trial court erred in excluding evidence and in jury instruction, as a prior fight between the two prisoners precluded them being joint venturers.
The Court held that while Mass. Gen. Laws ch. 269 §§ 1 and 7 provide for criminal penalties for riotous conduct damaging property, §§ 2, 3, 4, 5, 6 and 8 conflicted by omitting riots at prisons. The Court further held the statutory sections must be read in conjunction, finding that the conflict warranted reversal of all convictions except the convictions for causing injury to a penal institution.
Camara's conviction of hostage taking was upheld, as the trial court did not error. The convictions that were affirmed were ones filed with both prisoners' consent at trial. See: Commonwealth v. Spearin, 446 Mass. 599, 846 N.E.2d 390 (2006).
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Related legal case
Commonwealth v. Spearin
| Year | 2006 |
|---|---|
| Cite | 446 Mass. 599, 846 N.E.2d 390 (2006) |
| Level | State Supreme Court |
| Injunction Status | N/A |