After Aaron Hernandez died by suicide in 2017, his 2015 conviction for the murder of Odin Lloyd was overturned. The verdict was vacated because of a Massachusetts law that abates convictions in cases where the defendant dies before having the opportunity to see out the appeals process. Today, the state Supreme Judicial Court reinstated Hernandez’s conviction, and in the process effectively did away with the practice that had it overturned in the first place.
The court’s ruling argues that the application of the legal principle that led to Hernandez’s conviction being overturned, the doctrine of abatement ab initio, is an antiquated practice that was never officially adopted as law by the state, and was only applied previously because it was “the practice elsewhere.” The ruling states that the principle will no longer be applied from this point forward:
As we have been unable to discern a reasoned analysis for the adoption of the abatement ab initio doctrine, and in any event, we are presented with substantial reasons it should be changed, we conclude that we will no longer follow the doctrine when a defendant dies during the pendency of a direct appeal as of right challenging a conviction. Instead, upon the death of the defendant, the appeal shall be dismissed as moot and the trial court shall be instructed to place in the record a notation stating that the defendant’s conviction removed the defendant’s presumption of innocence, but that the conviction was appealed and it was neither affirmed nor reversed on appeal because the defendant died while the appeal was pending and the appeal was dismissed.
In September of 2018, Odin Lloyd’s mother settled a wrongful death lawsuit against Hernandez’s estate, the details of which were not made public. When Hernandez’s conviction was originally overturned, there was speculation that his legal status as an innocent man would hurt Lloyd’s mother’s chances at winning her civil suit.