Massachusetts Euthanasia Case: Of Pleas and Precedents

A defendant’s admission of sufficient facts to warrant a finding of guilt on a criminal charge, such as one made by Elliot S. Saffran, a Massachusetts horse owner charged with animal cruelty, sounds a lot like a guilty plea. Unlike a guilty plea, however, Saffran's admission might result in no criminal conviction on the charges.

Similar to diversion programs in many states, a Massachusetts Rule of Criminal Procedure allows a criminal defendant to enter a plea of not guilty, then subsequently admit that the prosecution presented sufficient facts to justify a verdict of guilty. The procedure, called a "continuance without a finding," allows the defendant to request a particular disposition of the criminal case. The proposed disposition can include a request that the court postpone a final judgment in the case for a period of time instead of an immediate finding of guilt.

In Saffran's case (read more), a state court judge agreed to continue the matter for two years, placing the defendant on supervised probation. The probationary period includes several conditions. If Saffran satisfies all the conditions, the criminal charges against him will be dismissed after two years--in effect, a finding of not guilty. If he violates any of the conditions, however, the court has the option of finding him guilty and imposing a prison sentence.

Because the district court retains jurisdiction over the case during the probationary period, without a decision about the defendant’s guilt or innocence. Without a final resolution, a continuance without a finding has no value as legal precedent for future cases. Nor, generally, does a case resolved by a guilty plea.

One of the fundamental tenets of the American legal system is adherence by courts to prior decisions in cases with facts similar to the matter at issue. Generally, though, a case has value as precedent only when there has been a determination of relevant facts at a trial, and when the trial verdict has been affirmed on appeal. A guilty plea short circuits the trial process, and a defendant who enters a plea gives up most rights to appeal.

About the Author

Milt Toby, JD

Milt Toby is an author and attorney who has been writing about horses and legal issues affecting the equine industry for more than 40 years. Former Chair of the Kentucky Bar Association's Equine Law Section, Milt has written eight nonfiction books, including national award winners Dancer’s Image and Noor. He teaches Equine Commercial Law in the University of Louisville's Equine Industry Program.

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