Santana v. Commonwealth

After a jury trial in Superior Court, Angel Santana was convicted of trafficking cocaine in the amount of fourteen to less than twenty-eight grams, in violation of G. L. c. 94C, § 32E(¿>), and trafficking in cocaine within 1,000 feet of a school zone, in violation of G. L. c. 94C, § 32J. This court vacated the judgments, concluding that the evidence was insufficient to establish that Santana constructively possessed the cocaine.1 Santana subsequently filed a complaint pursuant to G. L. c. 258D, the erroneous conviction statute. After discovery, the Common*554wealth moved for judgment on the…