United States v. Merritt, No. 13-1622 (1st Cir. 2014)
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This case arose from the misconduct of Annie Dookhan, a chemist at a Massachusetts state testing laboratory, who falsely certified drug testing results. Appellant was indicted for possession of crack cocaine with intent to distribute. Appellant pleaded guilty to the charge, but when news broke about Dookhan’s perfidy, Appellant moved to withdraw his plea. The district court denied relief, concluding that Appellant had not shown that Dookhan’s misconduct was material to his guilty plea. The First Circuit Court of Appeals affirmed, holding that the district court did not abuse its discretion in finding no fair and just reason for allowing Appellant to withdraw his guilty plea.
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