Commonwealth v. Baez

The Supreme Judicial Court held that, in light of Miller v. Alabama, 567 U.S. 460 (2012), juvenile delinquency adjudications for violent offenses may serve as predicate offenses for adults under the Armed Career Criminal Act (ACCA), Mass. Gen. Laws ch. 269, 10G.Defendant was indicted at age eighteen for unlawful possession of a firearm. Defendant had twice between adjudicated delinquent for crimes of violence, and therefore, the Commonwealth charged Defendant with violating the ACCA. While the case was proceeding, a superior court judge sua sponte raised the issue of whether it was a violation of due process to use juvenile adjudications to enhance sentencing in the same manner as adult convictions. The Supreme Judicial Court allowed Defendant’s application for direct appellate review and held that qualifying juvenile adjudications may be used as a predicate offense for enhanced penalties under Mass. Gen. Laws ch. 269, 10G. View "Commonwealth v. Baez" on Justia Law