Massachusetts State Police Colonel Geoffrey Noble said in July that Michael Proctor had worked hundreds, if not thousands, of cases, and that every single one needs to be looked at.
In a Dedham courtroom this week, that sentence stopped being an abstraction. A Norfolk County judge is hearing evidence on whether a first-degree murder indictment should be thrown out because Proctor led the investigation.
This is the first real test of what happens to the rest of his work, and however it comes out, it will shape the ones that follow.
The case
Marquis Simmons, 25, was shot in the chest on Belvoir Road in Milton on July 10, 2021, after stopping his moped. Before he died at the hospital, he identified the man who shot him by a nickname.
Myles King was arraigned in Quincy District Court two days later. A Norfolk County grand jury indicted him that November on first-degree murder, carrying a firearm without a license, carrying a loaded firearm without a license, and possession of a large-capacity firearm. A second defendant was indicted as an accessory after the fact.
Proctor was the lead investigator. He handled the scene, conducted interviews, wrote search warrants, and reviewed video.
How the motion got here
The original motion to dismiss, filed in May 2025, had nothing to do with bias. It was about discovery.
After a new prosecutor took over the case, hundreds of pages of material were turned over to the defense, including search warrants Proctor had authored. That happened years into the case and after the Commonwealth had already certified that discovery was complete. King was released on $10,000 cash bail in June 2025 in the wake of it. He was later charged federally with drug trafficking, and his state bail was revoked.
Then the phone came out.
Materials taken from Proctor’s personal phone were disclosed to the defense and revealed years of racist text messages, some more than a decade old, exchanged in a group chat that included a former Canton police sergeant. Reported excerpts describe fantasies of lynching a Black man by dragging him behind a vehicle, of burning a cross, and of killing Black people on sight, along with degrading imagery. We are not reproducing the language here; the substance is what matters legally.
Defense attorney Rosemary Scapicchio supplemented the motion to argue that Proctor held views so fundamentally racist and opposed to King as a Black man that the entire investigation was tainted, and that this constitutes egregious governmental misconduct requiring dismissal.
The supplemental motion was impounded at first. Judge Michael P. Doolin unsealed it in June, with limited redactions. Prosecutors assented to unsealing. Proctor opposed it on privacy grounds and lost.
What happened this week
The evidentiary hearing resumed Wednesday and Thursday, and the witness was Adam Lally, the assistant district attorney who originally prosecuted the case and who also prosecuted Karen Read.
Scapicchio spent the session on the discovery failures rather than on the texts: why hundreds of pages, including Proctor’s own search warrants, were not produced despite court orders and despite certifications that everything had been turned over. The question underneath it is whether the Commonwealth’s team knew what it had and when.
That focus is deliberate, and it points at the harder legal problem the defense faces.
Why dismissal is difficult, even here
Massachusetts law does not dismiss indictments to punish police. It dismisses them to protect a defendant’s right to a fair trial, which is a narrower thing.
The governing case is Commonwealth v. Lewin, 405 Mass. 566, decided in 1989. There, police misconduct included perjury and fabrication, and the Supreme Judicial Court still held that misconduct alone does not automatically warrant dismissal. The question is whether the defendant can still receive a fair trial. Dismissal is a drastic remedy, available when lesser sanctions cannot cure the harm.
The counterweight is Commonwealth v. Manning, 373 Mass. 438, from 1977, where the SJC dismissed with prejudice after government agents deliberately interfered with the defendant’s right to counsel. Manning is the shape of case that wins: intentional government conduct that damaged the defense itself, not conduct that merely discredits an officer.
So Scapicchio has two available theories, and they are not equally strong.
The bias theory is the one that generates headlines: an investigation conducted by someone who wrote what Proctor wrote cannot be trusted. It is also the harder one, because under Lewin the court will ask what specifically was corrupted. Which interview, which warrant, which piece of evidence would have come out differently. A dying man identified his shooter by name before Proctor did anything.
The discovery theory is less dramatic and more dangerous to the Commonwealth. Late disclosure of exculpatory or impeaching material is a documented, concrete deprivation with a measurable effect on trial preparation, and it comes with a record of certifications that turned out to be wrong. That is why the defense spent this week questioning a prosecutor rather than arguing about a fired trooper’s phone.
The part that reaches beyond one defendant
Proctor was fired in March 2025 after a trial board found unsatisfactory performance, including sending derogatory texts about Karen Read while leading her investigation and sharing sensitive case information with people outside law enforcement. He withdrew his appeal in October 2025. The POST Commission suspended his certification that December.
None of that resolves the cases he touched.
When a police officer is found to have lied, shown bias, or engaged in misconduct, prosecutors acquire disclosure obligations under Brady and Giglio in every case where that officer is a witness or an investigator. The information has to be handed over, and it has to be handed over in old cases as well as pending ones. The Committee for Public Counsel Services has demanded that the Norfolk district attorney produce a list of the cases Proctor worked.
Colonel Noble’s estimate of hundreds, if not thousands, is the scale of that problem. Most of those cases will not be dismissed. Many closed years ago with pleas. But every one of them now carries a disclosure question, and defendants who pleaded guilty without ever learning what the lead investigator had written have a colorable argument they were denied information they were entitled to.
Massachusetts has been here before. The Annie Dookhan and Sonja Farak drug lab scandals ultimately produced tens of thousands of vacated convictions, not because every test was wrong, but because the system could not certify which ones were right. The Proctor review is far smaller and factually different. The structural question is the same one: what does a court do when it cannot tell which cases were affected?
What to watch
Judge Doolin’s ruling on the motion to dismiss is the first data point. A dismissal would be extraordinary and would immediately become the template for every other Proctor case. A denial, which the case law makes more likely, would not end anything either. It would push the fight to trial, where the texts become impeachment material in front of a jury rather than grounds to end the case beforehand.
The second thing to watch is whether the district attorney’s office produces the case list, and what happens when defense lawyers start reading it.
For related coverage, see our explainer on how to look up a Massachusetts court case and our guide to CORI and record sealing.
Common questions
Who is Michael Proctor?
A former Massachusetts State Police trooper who was the lead investigator in the Karen Read case and in other homicide investigations. He was fired in March 2025 after a trial board found unsatisfactory performance, withdrew his appeal in October 2025, and had his certification suspended by the POST Commission in December 2025.
Can a murder case be dismissed because of police misconduct?
Rarely. Under Commonwealth v. Lewin, misconduct alone is not enough; the defendant must show it prevents a fair trial. Dismissal is treated as a drastic remedy when lesser sanctions cannot cure the harm.
How many cases did Michael Proctor work on?
MSP Colonel Geoffrey Noble said publicly in July 2026 that Proctor had worked hundreds, if not thousands, of cases, and that all of them need review. An exact number has not been published.
What are Brady and Giglio obligations?
Prosecutors must disclose evidence favorable to the defense, including information that could be used to impeach a government witness. Established misconduct or bias by an investigating officer generally triggers disclosure in every case that officer touched.
Does this mean convictions will be overturned?
Not automatically. Each case requires its own showing. The nearest Massachusetts precedent for mass relief is the drug lab litigation, which turned on the inability to identify which cases were affected.
Myles King is presumed innocent and has not been convicted. Allegations described here are contentions by the parties and have not been resolved.