Commonwealth v. Bowen

*793In Commonwealth v. Sayyid, 86 Mass. App. Ct. 479, 17 N.E.3d 469 (2014), this court held that a defendant's agreement to waive a probation violation hearing must be knowing and voluntary. Id. at 480, 489, 17 N.E.3d 469. Here, we are asked to determine whether a defendant's stipulation during a probation violation hearing to two alleged violations constituted a breach of due process within the meaning of Sayyid. We hold that the stipulation did not fall within the ambit of Sayyid, and we discern no due process violation. Accordingly, we affirm.

*794Background. 1. Convictions and alleged probation…