No Damages After Drug Lab Scandal Sinks Case, Court Says

By Julie Manganis | April 10, 2024, 7:20 PM EDT ·

A Massachusetts man is not entitled to compensation from a fund for exonerees after his 2006 heroin distribution conviction was among thousands of drug cases vacated due to misconduct by a chemist at the state crime lab, an intermediate appeals court said Wednesday.

The Appeals Court, in an unpublished opinion, rejected Daniel Knight's argument that the dismissal of his case "inferentially established his innocence," saying that nothing in the order dismissing cases linked to the Amherst drug lab suggests any evidence that he did not commit the crime.

The Appeals Court also pointed to a previous ruling by the state's top court, the Supreme Judicial Court, in a case involving another defendant who sought to apply the time he served for a vacated drug case toward a sentence for a later conviction. The SJC found that while the misconduct at the Amherst lab was "egregious," government misconduct does not imply innocence.

Knight had made a claim under the state's Compensation for Erroneous Felony Convictions statute, which covers people whose convictions have been set aside or reversed based on "grounds which tend to establish the innocence" of the defendant. He was appealing a Berkshire Superior Court justice's 2022 dismissal of that claim.

Knight spent 11 months in a Berkshire County jail after pleading guilty to a three-count indictment charging him with two counts of heroin distribution, a felony, and heroin possession. He later spent a year in custody for violating his probation.

Several years later, in 2011, Knight was charged in a theft and firearms case. Because of the previous felony convictions in the heroin case, he was subject to a state armed career criminal sentencing enhancement – something Knight argues would not have been in play but for the tainted 2006 case.

More than a decade later, after revelations that Amherst drug lab chemist Sonja Farak had stolen and used seized drugs submitted by police for testing, his conviction was among those wiped away as a global remedy for the misconduct.

Knight sued the state in 2021, seeking compensation under the erroneous-conviction law. Besides arguing that he qualified based on the inference of innocence, Knight argued that he met the criterion of having served more than a year in custody based on the subsequent probation violation sentence.

Knight and his lawyers argued that in addition to the sentencing enhancement he faced in his 2011 case, the 2006 conviction cost him his job, his residence, and his driver's license, and contributed to the loss of his parental rights.

Berkshire County Superior Court Justice John Agostini granted the state's motion to dismiss the claim in 2022, writing that "nothing in the dismissal of the defendant's three convictions, or the facts and circumstances underlying that relief, tends to show that he was innocent."

In its decision Wednesday affirming Justice Agostini's decision, the court said that because it shared the view that vacating Knight's sentence did not demonstrate actual innocence, it did not need to consider whether his initial 11-month sentence qualified him for compensation under the statute.

The Attorney General's Office declined to comment on the decision Wednesday.

A message seeking comment from Knight's counsel did not immediately receive a response.

Justices Robert A. Brennan, Christopher P. Hodgens and Sookyoung Shin sat on the panel for the Appeals Court.

Knight is represented by Elizabeth J. Quigley and Jonathan Thomas Zepka of Elizabeth J. Quigley & Associates.

The government is represented by Andrew Martin Batchelor of the Office of the Attorney General of the Commonwealth of Massachusetts.

The case is Knight v. Attorney General, case number 22-P-765, in the Appeals Court of the Commonwealth of Massachusetts.

--Editing by Peter Rozovsky.

Hello! I'm Law360's automated support bot.

How can I help you today?

For example, you can type:
  • I forgot my password
  • I took a free trial but didn't get a verification email
  • How do I sign up for a newsletter?
Ask a question!