Not Safe for Work: Greater Sanctions for Racially Motivated Prosecutorial Misconduct

On June 6, 2023, the Massachusetts Bar Counsel filed a Petition for Discipline against prosecutors John Bradley and Karen O’Sullivan for their racially motivated misconduct in the case of Commonwealth v. Choy. In September 2025, a Hearing Committee for the Massachusetts Board of Bar Overseers (BBO) recommended suspensions for Bradley and O’Sullivan. The Massachusetts BBO and Massachusetts Supreme Judicial Court (SJC) now have the opportunity to set precedent by suspending Bradley and O’Sullivan, as racially motivated prosecutors rarely receive bar sanctions. This Note explores the novel sanctions Bradley and O’Sullivan face. Additionally, this Note analyzes the special professional and ethical duties of a prosecutor, the role of race in wrongful convictions, and the infrequency of bar sanctions for racially motivated prosecutors. Finally, this Note argues that to prevent racially motivated wrongful convictions, bar associations must reform current disciplinary rules and processes to better hold prosecutors like Bradley and O’Sullivan accountable.