Commonwealth v. Edwards
476 Mass. 341
| Mass. | 2017Background
- At ~1:30 A.M., a named 911 caller (Jabari Wattley) told police he saw Joshua Edwards holding a gun, drive off in a black vehicle, return, get out holding the gun, then reenter the vehicle and sit with lights off.
- Officer Lanteigne responded to the broadcast, was pointed to a black Acura parked on a quiet residential street near a high-crime area, and perceived the car’s brake lights illuminate as if it might leave.
- Lanteigne activated cruiser lights and blocked the Acura; Edwards exited the vehicle and attempted to walk away, ignored commands, resisted, and was physically restrained and handcuffed.
- Another officer, at the driver’s-side window, observed a firearm on the driver’s-side floor; police then towed the car and conducted an inventory/search, seizing the firearm and open containers of alcohol.
- The motion judge granted suppression, finding the stop lacked reasonable, articulable suspicion; the SJC (affirming Appeals Court reversal) concluded the stop narrowly met reasonable suspicion and vacated suppression.
Issues
| Issue | Commonwealth's Argument | Edwards' Argument | Held |
|---|---|---|---|
| Whether the activation of cruiser lights and blocking of the Acura constituted a seizure requiring reasonable suspicion | Stop was supported by Wattley’s identified eyewitness 911 report plus police observations (time, location, conduct) giving rise to reasonable suspicion of criminal activity | Wattley’s report of seeing a man with a gun, and mere possession of a firearm, did not establish reasonable suspicion to stop the vehicle | Held: The stop was a seizure and, viewed collectively, the 911 report plus circumstances narrowly established reasonable suspicion |
| Whether officer conduct (blocking, drawing weapon, physical restraint) was proportional to the suspicion | Actions were reasonable and proportionate given risk, late hour, high-crime area, and defendant’s flight/resistance | Conduct exceeded permissible scope of a Terry stop and converted it to an arrest lacking probable cause | Held: Measures (blocking, restraint) were justified and proportional to escalating suspicion |
| Whether entry/search/seizure of vehicle was lawful (plain view / protective search / inventory) | Observation of gun in plain view justified further protective intrusion; once lawful access, plain-view seizure of gun and open containers lawful; inventory justified towing | Search exceeded scope absent probable cause or warrant; inventory improper when pretextual | Held: Protective intrusion and seizure of the gun were justified; plain-view seizure of open containers also lawful |
| Whether the informant’s reliability sufficed to justify reliance on the broadcast | Identified caller who personally witnessed the events and later pointed out the vehicle, therefore sufficiently reliable for reasonable suspicion | Caller’s report was insufficiently detailed (no description of gun; inconsistent vehicle make) and thus unreliable | Held: Caller’s identification, basis of knowledge, and in-person pointing out of vehicle rendered the tip sufficiently reliable for reasonable suspicion |
Key Cases Cited
- Terry v. Ohio, 392 U.S. 1 (1968) (authorizes brief investigatory stops based on reasonable, articulable suspicion)
- Commonwealth v. Alvarado, 423 Mass. 266 (1996) (defines reasonable-suspicion standard for vehicle stops)
- Commonwealth v. Thompson, 427 Mass. 729 (1998) (seizure occurs when officer blocks vehicle and suspect is not free to leave)
- Commonwealth v. Haskell, 438 Mass. 790 (2003) (fact pattern where loading a gun supported suspicion; distinguishes mere possession)
- Commonwealth v. Silva, 366 Mass. 402 (1974) (permitting threshold inquiries and limited intrusion into vehicles for officer safety)
- Commonwealth v. Robbins, 407 Mass. 147 (1990) (protective frisk and minimal vehicle search for weapons permissible for officer safety)