── R.D. v. Commonwealth ──
Court: Massachusetts Supreme Judicial Court
Date: May 21, 2026
Category: General
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SJC-13774
R.D. vs. COMMONWEALTH.
Suffolk. January 7, 2026. - May 21, 2026.
Present: Budd, C.J., Gaziano, Wendlandt, Georges, Dewar,
& Wolohojian, JJ.
Supreme Judicial Court, Superintendence of inferior courts. Due
Process of Law, Substantive rights, Competency to stand
trial, Pretrial detainees, Commitment. Practice, Criminal,
Competency to stand trial, Defendant's competency. Bail.
Civil action commenced in the Supreme Judicial Court for
the county of Suffolk on April 2, 2025.
The case was heard by Kafker, J.
Michaela R. Martin Strout, Committee for Public Counsel
Services, for the petitioner.
Kenneth E. Steinfield, Assistant District Attorney, for the
Commonwealth.
Tatum A. Pritchard, Justin M. Woolf, Deborah A. Dorfman,
Jennifer Honig, Steven Schwartz, & Kathryn Rucker, for
Disability Law Center, Inc., & others, amici curiae, submitted a
brief.
GEORGES, J. This is a companion case to S.W. v.
Commonwealth, 497 Mass. (2026), also decided today. The
2
defendant1 filed a petition in the county court pursuant to G. L.
c. 211, § 3, seeking relief from two orders issued by a judge of
the Boston Municipal Court. Specifically, the judge ordered the
defendant's hospitalization for a competency evaluation
(commitment order) pursuant to G. L. c. 123, § 15 (b)
(§ 15 [b]), and her detention without bail pending that
evaluation (detention order). Exercising his discretion to
reach the merits of the petition, a single justice of this court
allowed the petition in part, vacating the detention order while
denying relief as to the commitment order. The defendant
appealed. We affirm.2
Background. On March 31, 2025, the defendant was arrested
and charged with assault and battery on a family or household
member, in violation of G. L. c. 265, § 13M (a). She was
brought to the Roxbury Division of the Boston Municipal Court
Department (BMC) for her initial appearance. After being
informed by court officers that the defendant was acting
"bizarrely" in lockup and refusing to enter the court room for
1 Although this appeal stems from R.D.'s G. L. c. 211, § 3,
petition in the county court, for ease of reference we refer to
her as the defendant.
2 We acknowledge the amicus brief in support of the
defendant submitted by the Disability Law Center, Inc., the
Mental Health Legal Advisors Committee, the Center for Public
Representation, and the Massachusetts Association for Mental
Health.
3
her arraignment, her defense counsel requested that she be
evaluated for competency, pursuant to G. L. c. 123, § 15 (a)
(§ 15 [a]). However, no clinician was available at that time.
The judge ordered that the defendant be held without bail
overnight and continued the case to the following day for the
evaluation.
The next day, a court clinician evaluated the defendant. A
different judge then held a hearing at which the court clinician
testified. The clinician reported that, during the competency
evaluation, the defendant apologized several times, appeared
fearful, and told the clinician that she "[did] not want to
participate in the evaluation." The clinician further testified
that, five weeks prior to the defendant's arrest, her father had
taken her to the emergency room of a Boston hospital because she
was exhibiting pa