Preview:

Commonwealth v. Billings Opinion Summary: Defendant was convicted of unlawful distribution of cocaine and of a drug offense in a school zone. The Appeals Court, relying on its decision in Commonwealth v. King, affirmed defendant's convictions, holding that a field test and other circumstances rendered the admission of the certificate of drug analysis harmless beyond a reasonable doubt. The court granted defendant's application for further appellate review and paired this case for argument with Commonwealth v. King, a case that raised the same issue and involved the same prosecutor and the same detective as were involved in this case. Because the court concluded, as it did in King, that in the specific circumstances of this case, the Commonwealth's evidence was not so overwhelming as to nullify the effect of the erroneously admitted certificate, the judgment was reversed.
COMMONWEALTH vs. Ronald L. BILLINGS.
SJC-10847.
October 3, 2011. - January 19, 2012.
Controlled Substances. Constitutional Law, Confrontation of witnesses. Evidence, Certificate of drug analysis.
Practice, Criminal, Confrontation of witnesses, Harmless error.

INDICTMENTS found and returned in the Superior Court Department on October 28, 2005.

The cases were tried before John P. Connor, Jr., J.

After review by the Appeals Court, the Supreme Judicial Court granted leave to obtain further appellate review.

Elizabeth Doherty for the defendant.

Mary E. Lee, Assistant District Attorney, for the Commonwealth.

Present: Ireland, C.J., Spina, Cordy, Botsford, Gants, & Duffly, JJ.

IRELAND, C.J.

In 2006, a jury convicted the defendant of unlawful distribution of cocaine and of a drug offense in a school zone, in
violation of G.L. c. 94C,

Download sjc-10847.pdf

Massachusetts Law