Commonwealth v. Cornelio L. Conley.

Massachusetts Appeals Court·Decided January 15, 2026·No. 24-P-0849·Unpublished

Opinion

NOTICE: Summary decisions issued by the Appeals Court pursuant to M.A.C. Rule 23.0, as appearing in 97 Mass. App. Ct. 1017 (2020) (formerly known as rule 1:28, as amended by 73 Mass. App. Ct. 1001 [2009]), are primarily directed to the parties and, therefore, may not fully address the facts of the case or the panel's decisional rationale. Moreover, such decisions are not circulated to the entire court and, therefore, represent only the views of the panel that decided the case. A summary decision pursuant to rule 23.0 or rule 1:28 issued after February 25, 2008, may be cited for its persuasive value but, because of the limitations noted above, not as binding precedent. See Chace v. Curran, 71 Mass. App. Ct. 258, 260 n.4 (2008).

COMMONWEALTH OF MASSACHUSETTS

APPEALS COURT

24-P-849

COMMONWEALTH

vs.

CORNELIO L. CONLEY.

MEMORANDUM AND ORDER PURSUANT TO RULE 23.0

The defendant, Cornelio L. Conley, was convicted after a

jury trial in the Boston Municipal Court of one count of assault

and battery on a police officer and one count of resisting

arrest. On appeal, he challenges only his conviction for

resisting arrest, arguing that the evidence was insufficient and

that two leading questions to the Commonwealth's police officer

witnesses created a substantial risk of a miscarriage of

justice. We affirm.

Background. A number of Boston police officers were

dispatched to the Boston Public Library. The first to arrive,

Officer Arthur Green, who was in uniform, told the defendant "to

turn around and put his hands behind his back." While Green did not tell the defendant that he was under arrest, he testified

that "when you place somebody under arrest, you tell them to

turn around and put their hands behind their back." The

defendant did not comply; instead, he "[w]hipped" a tarp in

Green's direction, hitting him in the face. Green then sprayed

the defendant with pepper spray. The defendant, moving away

from Green, struck another responding officer, Green's partner,

in the face. The officers pursued the defendant, and a

prolonged struggle took place; after more officers arrived on

the scene, they were able to place the defendant in handcuffs.

Multiple officers sustained injuries during the altercation that

required medical treatment. The defendant also suffered

injuries to his face and ribs.

Discussion. 1. Sufficiency of the evidence. The

defendant contends the evidence was insufficient to support his

conviction of resisting arrest. We review the evidence in the

light most favorable to the Commonwealth to determine whether

any rational jury could have found the defendant guilty beyond a

reasonable doubt. See Commonwealth v. Latimore, 378 Mass. 671,

676-677 (1979).

"[T]he crime [of resisting arrest] is committed, if at all,

at the time of the 'effecting' of an arrest." Commonwealth v.

Grandison, 433 Mass. 135, 145 (2001), quoting G. L. c. 268,

2 § 32B. An "arrest" requires satisfaction of all three of the

so-called "Grandison elements": "[1] an actual or constructive

seizure or detention of the person, [2] performed with the

intention to effect an arrest and [3] so understood by the

person detained." Commonwealth v. Soun, 82 Mass. App. Ct. 32,

34 (2012), quoting Grandison, supra.

The defendant argues a rational jury could not have found

that police had effected an actual arrest -- only a mere

investigatory, or Terry-type stop -- at the time the defendant

put up the alleged resistance. See Commonwealth v. Grant, 71

Mass. App. Ct. 205, 209 (2008) ("Fleeing from, or even

resisting, a stop or patfrisk does not constitute the crime of

resisting arrest"); Commonwealth v. Smith, 55 Mass. App. Ct.

569, 574 (2002) ("A stop for purposes of making a threshold

inquiry is not an arrest"). The defendant contends the arrest

did not occur until the officers placed him in handcuffs, and

because the evidence does not include any acts of resistance

after this point, his motion for a required finding of not

guilty should have been allowed.

"In view of the direct testimony by [officer witness] of

the officers' intent to arrest" the defendant, we think "no

serious argument can be made that the second Grandison element

was not met." Soun, 82 Mass. App. Ct. at 36. Contrast Smith,

3 55 Mass. App. Ct. at 575-576 (evidence insufficient to support

conviction of resisting arrest where responding officer

"testified that his intent at the time was only to make a

threshold inquiry"). We focus on the first and third Grandison

elements.

a. Proof of seizure. "[A]n arrest may occur even if the

police do not make a formal arrest." Commonwealth v. Sanderson,

398 Mass. 761, 766 (1986). Furthermore, "police do not need to

use the word 'arrest' in order for there to be an arrest . . .

Rather, the test is whether a reasonable person would have

understood that he was under arrest." Commonwealth v. Quintos

Q., 457 Mass. 107, 111 (2010). Here, the jury could have found

that when Green approached the defendant and told him "to turn

around and put his hands behind his back," a reasonable person

in the defendant's position would have understood that Green

intended to effect an arrest by handcuffing him. See Soun, 82

Mass. App. Ct. at 35-36 ("A reasonable person would not have

felt free to walk away when Officer Parousis ordered him to turn

around and place his hands behind his back").

b. Understanding of person accused. "The standard for

determining whether a defendant understood that he was being

arrested is objective -- whether a reasonable person in the

defendant's circumstances would have so understood." Grant, 71

4 Mass. App. Ct. at 208. "While it is not necessary to use the

word 'arrest' when taking a defendant into custody, in most

instances there is some form of communication between the police

officer and the person" (quotations and citations omitted). Id.

at 209. See Soun, 82 Mass. App. Ct. at 36 ("Other phrases and

situations commonly associated with arrest can create the

required level of understanding").

In this case, following the officer's order to the

defendant to turn around and put his hands behind his back --

which "viewed objectively . . . is commonly associated with the

initial phase of an arrest," Soun, 82 Mass. App. Ct. at 36

-- the defendant acted belligerently toward officers, was pepper

sprayed and pursued, and engaged in a physical struggle with

multiple responding officers. Considering this combination of

circumstances in the light most favorable to the Commonwealth,

"a police command to turn around and put one's hands behind

one's back reasonably could not be understood as simply a

detention for a threshold inquiry." Id. at 37. The evidence

permitted the jury to find that a reasonable person in the

defendant's shoes would have understood he was under arrest

before he "[w]hipped" the tarp at Green, and certainly by the

time he struck the second officer and engaged in a struggle that

5 injured several others. The evidence was sufficient to support

the conviction of resisting arrest.

2. Leading questions. The defendant also argues his

conviction for resisting arrest should be reversed because the

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