Commonwealth v. Conaghan

In 1994, Deborah Conaghan pleaded guilty to manslaughter following the death of her son. At the plea hearing, Conaghan stated that she was entering her guilty plea freely and uncoerced. In 1999, Conaghan moved to withdraw the guilty plea and receive a competency examination. Conaghan alleged that she had been suffering from battered-woman syndrome, which rendered her mentally incompetent when she had entered the guilty plea. Conaghan argued that under Massachusetts General Law c. 123, § 15(a), she was entitled to a competency examination by an expert on battered-woman syndrome. In support of her motion, Conaghan submitted (1) an affidavit in which she detailed the abuse she and her son suffered from her partner, Paul Haynes; (2) her own psychiatric records since she began mental treatment, which contained a diagnosis of bipolar disorder and a tendency to be influenced by abusive men; (3) evidence that, after her guilty plea, Haynes was convicted of multiple counts of forcible rape of a child, assault, and battery, and that Conaghan had testified at his trial to the abuse that she and her son had suffered. The court of appeals denied the motion. Conaghan appealed. On appeal, the Commonwealth of Massachusetts (plaintiff) argued that the guilty plea should stand because the fact that Conaghan had waited to submit a competency claim affected her credibility.