Commonwealth v. Lyons

Massachusetts Supreme Judicial Court
492 N.E.2d 1142, 397 Mass. 644 (1986)

ELI5:

Rule of Law:

Evidence obtained as a result of an arrest that violates a purely statutory procedural requirement, but not a constitutional right, is not subject to suppression under the exclusionary rule, particularly when the violation was not an intentional act of misconduct by police.

Facts:

In January 1984, a woman was assaulted in Watertown.
Approximately ten weeks later, a security guard in the town of Bedford reported an incident of indecent exposure by the defendant to Bedford police.
A Watertown police detective, who was investigating a series of rapes, learned of the Bedford indecent exposure report and asked Bedford police to provide him with a photograph of the defendant if he was arrested.
On April 6, 1984, a Bedford police prosecutor applied for a complaint and an arrest warrant against the defendant for the indecent exposure charge.
The court clerk issued the arrest warrant without giving the defendant prior notice or an opportunity for a hearing, which was required by state statute G. L. c. 218, § 35A.
Following his arrest on the warrant, the defendant was routinely photographed at the police station.
On April 20, 1984, the victim of the January Watertown assault identified the defendant as her attacker after being shown a photographic array that included the picture taken after his arrest in Bedford.

Procedural Posture:

The defendant was indicted for crimes arising from an assault in Watertown.
The defendant filed a pretrial motion in the trial court to suppress the victim's in-court and out-of-court identifications of him.
The motion judge denied the defendant's motion to suppress.
The defendant appealed the denial of his pretrial motion to the Supreme Judicial Court of Massachusetts.

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Issue:

Does the failure to provide a defendant with a statutorily required, but not constitutionally required, opportunity to be heard before the issuance of an arrest warrant require the suppression of identification evidence derived from a photograph taken after that arrest?

Opinions:

Majority - Wilkins, J.

No. The failure to provide a statutorily required hearing does not require the suppression of identification evidence derived from the resulting photograph. The court reasoned that the violation was purely statutory, not constitutional. Neither the U.S. Constitution nor the Massachusetts Constitution requires a hearing before process can issue on a criminal complaint; the state constitution's 'law of the land' clause refers to due process, not the specifics of every state statute. The court declined to create an exclusionary rule for a violation of G. L. c. 218, § 35A, because the statute is not closely associated with a fundamental constitutional right, and its violation does not cause substantial, lasting prejudice. Furthermore, the court emphasized that the error was attributable to negligence by the police prosecutor and court clerk, not intentional police misconduct intended to circumvent the defendant's rights. The case for applying the exclusionary rule is significantly weaker for negligent conduct and magisterial errors than for deliberate police misconduct.

Analysis:

This decision clarifies the scope of the exclusionary rule in Massachusetts by distinguishing between violations of constitutional rights and violations of purely statutory procedures. The court establishes that not every procedural error by law enforcement or the judiciary warrants the suppression of evidence. This ruling limits the exclusionary rule's application, reinforcing its primary purpose as a deterrent against intentional police misconduct that violates fundamental rights, rather than as a remedy for every procedural mistake. Consequently, it makes it more difficult for defendants to suppress evidence obtained following technical, non-constitutional violations of law.

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