Commonwealth v. Mauricio, 477 Mass. 588

Mauricio was convicted in Taunton District Court of carrying a firearm without a license and receiving stolen property over $250; the firearms storyline arose from images on a digital camera found in his backpack during a stop.
Police detained Mauricio on suspicion of house burglary; they frisked him and searched his backpack, revealing the digital camera and other items.
At the station, an inventory of the backpack was conducted; the camera was turned on and its images viewed to identify the owner.
detectives showed a homeown er a photo from the camera’s images, linking the firearms in the images to a separate residential break-in.
The defense moved to suppress the camera images, arguing the police search was not a valid incident-to-arrest or inventory search; the trial judge denied the motions, with later reconsideration allowing the backpack items in under inevitable discovery, but the camera issue remained unresolved until appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the warrantless search of the digital camera was valid as a search incident to arrest.	Mauricio (Commonwealth) argues it falls within search incident to arrest under art.14/US Const.	Mauricio contends Riley controls and excludes data searches from incident-to-arrest; data on the camera cannot be searched incident to arrest.	Not valid under art.14; data search outside incident-to-arrest scope.
Whether the camera search was within the inventory search exception.	Commonwealth argues the camera was seized during a routine inventory.	Camera examination was investigatory, not a mere inventory.	Exceeds inventory scope; investigatory purpose; suppression warranted.
Whether the evidence supports a value in excess of $250 for the ring, or only $250 or less.	Commonwealth asserts the ring’s value exceeded $250.	Evidence lacking value testimony; photos alone insufficient to prove value.	Insufficient to prove value over $250; conviction reduced to $250 or less.

Riley v. California, 134 S. Ct. 2473 (U.S. 2014) (cell phone search incident to arrest not permitted; data privacy concerns heightened)
Commonwealth v. Madera, 402 Mass. 156 (Mass. 1988) (art. 14 scope; exclusionary principles applied under state constitution)
Commonwealth v. White, 475 Mass. 583 (Mass. 2016) (inventory searches; limits when investigative purpose evident)
Commonwealth v. Blood, 400 Mass. 61 (Mass. 1987) (art. 14 protective scope; private data concerns elevated)
Commonwealth v. Va Meng Joe, 425 Mass. 99 (Mass. 1997) (standards for appellate affirmance on alternative grounds)