Doyle v. Commonwealth

Summary

The Massachusetts Supreme Judicial Court affirmed the denial of Christopher S. Doyle’s petition under G. L. c. 211, § 3, and his request for habeas corpus relief. The court held that the asserted double jeopardy, duplicative-conviction, sentencing, and ineffective-assistance claims either were or could have been raised through ordinary appellate or postconviction procedures. It concluded that extraordinary superintendence and habeas corpus may not substitute for the normal trial, appeal, and postconviction processes.

Holdings

1. Relief under G. L. c. 211, § 3, was properly denied because the alleged errors either were or could have been raised on direct appeal or in a motion for postconviction relief under Mass. R. Crim. P. 30.
2. Habeas corpus relief was properly denied because the petition did not present grounds distinct from issues arising at the indictment, trial, conviction, or sentencing stages.
3. The court was not required to exercise its general-superintendence power to protect the constitutional right not to be tried because Doyle already had been tried and convicted.

Questions Presented

1. Whether relief under G. L. c. 211, § 3, was available when the asserted errors either were or could have been raised on direct appeal or in a motion for postconviction relief under Mass. R. Crim. P. 30.
2. Whether habeas corpus relief was available for claims arising from the indictment, trial, conviction, sentencing, or alleged ineffective assistance of counsel.
3. Whether the petitioner's double jeopardy claim required exercise of the court's general superintendence power after he had already been tried and convicted.

Disposition

affirmed