The Massachusetts Appeals Court considered a Rule 30 appeal over whether a defendant convicted in 2011 can benefit from later changes in Second Amendment doctrine and SJC retroactivity rulings (Commonwealth v. Ricardo Fields, 2024-1307). Counsel for Ricardo Fields argued the Commonwealth was required to prove beyond a reasonable doubt the absence of a firearms license at Fields's 2011 trial and that McDonald and Heller made that right fundamental.

Attorney Bennion, arguing for Fields, told the panel that trial counsel preserved the issue at trial and stressed that once a constitutional right is treated as fundamental and incorporated, the government must prove each element of an offense. "When incorporation occurs, that triggers some real due process protections for a criminal defendant," Bennion said, arguing those protections should apply on retroactivity grounds.

The court repeatedly queried whether the defendant was asking the panel to depart from the SJC's retroactivity decision in Guardado, which the Commonwealth said limits the benefit of Bruin to defendants whose convictions became final after Bruin. Assistant District Attorney Lindsay Conkey argued the SJC's Guardado decision sets the retroactivity rule the Appeals Court must follow and that Fields's conviction was final years before Bruin.

Substantive point: Bennion argued that Heller and McDonald established incorporated, fundamental Second Amendment protections and that later cases (transcript references to "Bruin") elaborated the government's burden; Bennion asked the panel to apply those protections despite the conviction date. The panel and Commonwealth counsel questioned whether preservation of the issue at trial affects retroactivity under Teague-based analysis and whether Guardado forecloses retroactive relief for convictions final before Bruin.

The panel pressed on precedent and doctrine: Justice Kenneth Desmond asked counsel to grapple with plain-language retroactivity rules and prior SJC decisions; Bennion argued that incorporation should not be parsed and that McDonald and Heller already vested the right. The Commonwealth said there was no Massachusetts authority that preserves an issue at trial automatically to overcome Guardado's retroactivity rule.

Ending: The court heard rebuttal and moved on; no decision was announced from the bench. The written opinion will resolve whether Fields can obtain relief for a conviction that became final before the SJC's Bruin decision.