Summary
The Massachusetts Supreme Judicial Court affirmed the denial, without a hearing, of Christopher Pike's petition under G. L. c. 211, § 3, seeking extraordinary relief from the denial of habeas corpus relief. The court held that Pike had adequate alternative remedies through direct appeal or a motion for a new trial and that habeas corpus could not substitute for ordinary appellate procedures. The court also concluded that the single justice did not abuse her discretion.
Topics
Practice areas
Questions Presented
- Whether the single justice abused her discretion by denying without a hearing Pike's petition for extraordinary relief under G. L. c. 211, § 3.
- Whether habeas corpus or relief under G. L. c. 211, § 3, was available to challenge the alleged improper dismissal of a juror during deliberations when ordinary appellate and postconviction remedies were available.
- Whether S.J.C. Rule 2:21 applied to Pike's appeal from the single justice's denial of relief.
Holdings
- S.J.C. Rule 2:21 did not apply because Pike was not challenging an interlocutory ruling of the trial court.
- The single justice did not abuse her discretion by denying Pike's G. L. c. 211, § 3, petition without a hearing.
- Habeas corpus was inappropriate because Pike's challenge went to the merits of his underlying criminal judgments and could have been pursued through ordinary appellate or postconviction procedures.
Key quotations
“In cases such as this one, where the single justice exercises discretion not to reach the merits of a petition, . . . the full court asks only whether the single justice abused his or her discretion in making that decision” (at 1012-1013)
“habeas corpus "cannot be employed as a substitute for ordinary appellate procedure"” (at 99, 101)
Factual background
In October 2022, a jury convicted Pike of multiple offenses, including indecent assault and battery on a child under fourteen, assault with intent to rape a child, aggravated rape of a child, furnishing alcohol to a minor, and accosting and annoying another person. Pike was sentenced to twelve to fourteen years in State prison, and the Appeals Court affirmed the judgments. He later challenged the trial judge's dismissal of a juror during deliberations through a habeas corpus petition and then through a G. L. c. 211, § 3, petition after the Superior Court denied habeas relief.
Procedural history
A jury convicted Pike in the Superior Court of multiple sex-related and alcohol-related offenses, and he received a State prison sentence of twelve to fourteen years. The Appeals Court affirmed his criminal judgments. Pike then filed a habeas corpus petition in the Superior Court, challenging the dismissal of a juror during deliberations; after that petition was denied, he sought relief under G. L. c. 211, § 3, from a single justice of the Supreme Judicial Court. The single justice denied the petition without a hearing, and the full court affirmed.