Commonwealth v. LeBlanc
475 Mass. 820
| Mass. | 2016Background
- Defendant Randy A. LeBlanc backed his pickup into a private driveway and struck the homeowner’s parked Chevrolet Cavalier; he admitted the collision to a friend and a police officer and then left without identifying himself.
- He was convicted, after a bench trial, under G. L. c. 90, § 24 (2)(a) for knowingly causing property damage and leaving the scene without identifying himself.
- The Appeals Court affirmed the conviction in a Rule 1:28 memorandum; the Supreme Judicial Court granted further review to decide whether § 24 (2)(a) requires the accident to have occurred on a public way.
- The statutory text contains multiple separate “whoever” clauses; the phrase describing “any way or in any place to which the public has a right of access…” appears only in the first clause.
- The question presented was whether that “public way” language operates as an element for the clause criminalizing leaving the scene after causing property damage.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether § 24(2)(a) requires accidents causing property damage to occur on a public way | Commonwealth: statute’s plain language governs; conviction valid without public-way requirement for the property-damage clause | LeBlanc: the public-way phrase should apply to the property-damage clause; otherwise statutory structure is incoherent and violates lenity if ambiguous | The public-way language appears only in the first clause and does not apply to the separate clause penalizing leaving after causing property damage; conviction affirmed |
| Whether statutory ambiguity requires applying the rule of lenity | Commonwealth: statute is unambiguous under ordinary grammar; no lenity needed | LeBlanc: prior dictum in Platt and subsequent confusion show ambiguity warranting lenity | Court finds statute unambiguous; rule of lenity does not apply |
| Whether importing a public-way element is required for coherence with other clauses (e.g., § 24(2)(a½)) | Commonwealth: legislative history shows property-damage clause has long lacked the public-way predicate; courts must apply text as written | LeBlanc: inconsistency with § 24(2)(a½) (which contains a public-way requirement) is unfair and irrational | Court declines to add language; recognizes inconsistency but says judiciary cannot rewrite statute; invites Legislature to amend if desired |
| Whether prior case dictum (Platt) controls | Commonwealth: Platt’s footnote was dictum and did not decide the issue; current case squarely presents it | LeBlanc: Platt caused confusion and supports reading a public-way element into the offense | Court treats Platt’s statement as dictum, clarifies the law, and resolves the issue contrary to that dictum |
Key Cases Cited
- International Fid. Ins. Co. v. Wilson, 387 Mass. 841 (discussing reliance on plain statutory language)
- Commissioner of Correction v. Superior Court Dep’t of the Trial Court for the County of Worcester, 446 Mass. 123 (clear statutory language controls)
- Rowley v. Massachusetts Elec. Co., 438 Mass. 798 (use of grammatical rules in statutory interpretation)
- Carter v. United States, 530 U.S. 255 (statutory clauses standing on their own and use of "whoever")
- United States Nat’l Bank of Oregon v. Independent Ins. Agents of Am., Inc., 508 U.S. 439 (statutory meaning follows punctuation)
- Lowery v. Klemm, 446 Mass. 572 (avoiding absurd or unreasonable statutory constructions)
- Commonwealth v. Platt, 440 Mass. 396 (prior dictum that contributed to confusion about elements)
- Commonwealth v. Constantino, 443 Mass. 521 (rule of lenity applies if a criminal statute is ambiguous)
- Commissioner of Revenue v. Cargill, Inc., 429 Mass. 79 (courts apply, not amend, statutory language)