Commonwealth v. Williams

Massachusetts Appeals Court · 2024 · Criminal Law

Criminal LawSearch and SeizureEvidenceJury SelectionFourth Amendmentart. 14backpack searchfirearm

Facts

Police investigating a July 2017 homicide had probable cause to arrest the defendant based on surveillance footage and an eyewitness identification. When officers arrested him more than three months later as he sat in a legally parked car, he had just entered the car wearing a backpack and left the backpack on the passenger seat when ordered out. After the defendant was handcuffed and removed, an officer took the backpack from the car and opened it, finding a handgun. Ballistics later matched that gun to shell casings from the murder scene, and the defendant's fingerprint was found on the gun's magazine.

Issue

Whether the warrantless seizure and search of the backpack, and the seizure of the handgun inside it, were lawful under the Fourth Amendment and art. 14 when the backpack was searched after the defendant had been arrested and removed from the scene. The appeal also asked whether peremptory strikes based on jurors' youth were unconstitutional and whether showing surveillance clips to an eyewitness during testimony was prejudicial error.

Rule

Police may search a vehicle and containers within it without a warrant when they have probable cause to believe evidence relevant to the crime of arrest is located there; that authority continues even after the arrestee has been secured and removed from the vehicle. In evaluating staleness, courts consider the nature of the criminal activity and the nature of the item sought, and durable items such as firearms may support probable cause even after a significant lapse of time. Age is not a constitutionally protected discrete group, so a peremptory challenge may permissibly be based on age.

🔒

See the holding & full analysis

Create a free KwikCourt account to unlock the rest of this brief — and practice the case.

The court's holding and reasoning
Doctrine tests, pitfalls & exam hypotheticals
10 practice questions + 4 AI-graded essays on this case

Free sample · practice this case

Test yourself

One of 10 multiple-choice questions for this case. Pick an answer to see why.

Police in Philadelphia have probable cause to arrest Nolan Price for a nightclub shooting captured on video. The video shows the shooter pull a pistol from his waistband, fire, and tuck it back into his waistband. Two months later, officers arrest Nolan as he sits in a legally parked sedan on a public street in South Philadelphia after watching him carry a messenger bag into the car and set it on the front seat; no gun is found on his person.

May officers open the messenger bag without a warrant after removing and handcuffing Nolan?

Explanation. The majority held that when police have probable cause to believe evidence relevant to the crime of arrest is in a vehicle in a public area, they may search the vehicle and containers within it without a warrant, and that authority continues even after the arrestee has been secured and removed. Here, the video-based probable cause, the absence of a gun on Nolan's person, and the fact that he had just carried the bag into the car make it reasonable to search the bag for the firearm. (Derived from Commonwealth v. Williams (n.d.).)