## Facts

- Deborah Conaghan pleaded guilty in Massachusetts Superior Court to manslaughter in the death of her young son.
- During the plea colloquy, Conaghan stated twice that she was pleading of her own free will and denied any threats or promises inducing the plea.
- The prosecutor recited Conaghan’s prior statement that she pushed her son when no one else was present and that similar punishments had occurred on several prior occasions.
- About four and one-half years later, Conaghan moved to withdraw her guilty plea (treated as a motion for a new trial) and sought a competency examination and public funds for an expert under G.L. c. 123, § 15(a).
- Conaghan supported the motions with materials asserting that (i) her former boyfriend, Paul Haynes, inflicted the fatal injuries, and (ii) battered woman syndrome and other mental-health problems affected her competence and made the plea involuntary.
- The submissions described a history of abuse by Haynes against Conaghan and her son and referenced mental-health records and diagnoses.
- Conaghan also relied on post-plea developments, including Haynes’s later convictions for sexual and violent crimes and her testimony about abuse at his trial.
- The motion judge denied a § 15(a) examination and denied plea withdrawal; the Appeals Court affirmed.

## Issues

1. Whether Conaghan’s postconviction showing raised a substantial question of competency requiring a court-ordered examination under G.L. c. 123, § 15(a), particularly by an expert in battered woman syndrome, before deciding her motion to withdraw the plea.
2. Whether the four and one-half year delay in seeking a competency-based examination justified denying the request as insufficiently credible.

## Decision

- The Supreme Judicial Court vacated the order denying a § 15(a) competency examination and remanded for an examination by an expert in battered woman syndrome and further proceedings.
- The court held the motion to withdraw the plea could not properly be decided on the existing record without specialized expert evaluation bearing on competency and the ability to enter a voluntary and intelligent plea.
- The court rejected the argument that the passage of four and one-half years, in the circumstances presented, rendered the competency claim less credible or justified refusal to order the examination.
- The court did not decide whether Conaghan was incompetent or whether the plea must be withdrawn; it required development of an expert record first.

## Legal Principles

- A post-sentence motion to withdraw a guilty plea is treated as a motion for a new trial under Mass. R. Crim. P. 30(b).
- A guilty plea is valid only if voluntary, intelligent, and made with sufficient awareness of the circumstances and the advice of competent counsel.
- A plea is void if involuntary or unintelligent for any reason, including incompetence at the time of the plea.
- Competency is assessed by whether the defendant had sufficient ability to consult with counsel with a reasonable degree of rational understanding and had a rational and factual understanding of the proceedings.
- When a substantial question of competency is raised, the court must order an examination under G.L. c. 123, § 15(a); where battered woman syndrome is the asserted basis, an examiner with relevant specialized expertise may be required.
- A defendant’s plea-colloquy assurances of voluntariness are important but may not be conclusive when later materials plausibly indicate an unaddressed mental condition affecting competency and voluntariness.
- Delay in raising a competency-based challenge does not automatically defeat the request where the circumstances and the asserted condition plausibly explain the timing and support the need for evaluation.

## Conclusion

The Supreme Judicial Court held that Conaghan’s submissions raised a substantial competency question tied to battered woman syndrome, requiring a § 15(a) examination by a qualified expert before adjudicating her plea-withdrawal motion, and that the multi-year delay alone did not justify denying the examination.


Commonwealth v. Conaghan, 433 Mass. 105 (2000)