Commonwealth v. Jason Oliver.

CourtMassachusetts Appeals Court
DecidedJune 16, 2025
Docket24-P-0688
StatusUnpublished

This text of Commonwealth v. Jason Oliver. (Commonwealth v. Jason Oliver.) is published on Counsel Stack Legal Research, covering Massachusetts Appeals Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Commonwealth v. Jason Oliver., (Mass. Ct. App. 2025).

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-688

COMMONWEALTH

vs.

JASON OLIVER.

MEMORANDUM AND ORDER PURSUANT TO RULE 23.0

A Superior Court judge denied the defendant's motion to

suppress the fruits of an entry into his home to serve an arrest

warrant, as well as the fruits of a subsequent consent search of

the home, including a firearm and cocaine. The defendant then

entered conditional guilty pleas to charges of unlawful

possession of a firearm and ammunition and possession of cocaine

with intent to distribute. The defendant now appeals the order

denying his motion to suppress, contending that (1) the entry

into his home was based on unreliable hearsay and was

accomplished without police knocking and announcing themselves;

(2) police conducted a protective sweep of the home without

reasonable basis; (3) his girlfriend's subsequent consent to a search of the home was coerced and thus invalid; (4) the judge

at the suppression hearing inappropriately allowed the

Commonwealth to present much of its evidence on rebuttal; and

(5) the claimed dismissal of certain Rhode Island charges

against the defendant required suppression of the evidence here.

We affirm.

Background. A Rhode Island court issued an arrest warrant

for the defendant on four felony cocaine charges. Because the

defendant's last known address was in Fall River, the Rhode

Island State police (RISP) placed the arrest warrant into a

tracking system for extradition. That system listed the

defendant's name, date of birth, social security number,

description, Massachusetts license number, and Fall River

address ("the address"), as well as his alias, "Gunz."

The warrant came to the attention of the Massachusetts

State police (MSP), who were further informed that the defendant

was president of the newly formed Massachusetts chapter of the

Pagans, a motorcycle club, was highly likely to have guns in his

possession, and had been placed at the address several times. A

MSP lieutenant applied to a District Court and obtained a

fugitive arrest warrant. The lieutenant also learned from a

Registry of Motor Vehicles (RMV) record check that the defendant

listed the address on his driver's license. Police then

executed the warrant at the address, arrested the defendant,

2 discovered a firearm during a protective sweep, obtained his

girlfriend's signature on a form consenting to a search of the

home, conducted the search, and seized the firearm, as well as

cocaine found in a bathroom. The defendant was indicted, and

filed a motion to suppress, which the judge denied after a

lengthy evidentiary hearing.

We address the defendant's five claims in turn. In

reviewing the suppression ruling, "we adopt the motion judge's

factual findings absent clear error," Commonwealth v. Isaiah I.,

450 Mass. 818, 821 (2008), and "conduct an independent review of

his ultimate findings and conclusions of law." Commonwealth v.

Jimenez, 438 Mass. 213, 218 (2002).

1. Entry into home. The defendant asserts that police

lacked a reasonable belief that he lived at the address and that

he was home at the time. Police may enter a home to serve an

arrest warrant if they "have a reasonable belief that the

location to be searched is the arrestee's residence, and a

reasonable belief that the arrestee is in his residence at the

time the arrest warrant is executed." Commonwealth v. Gentile,

466 Mass. 817, 818 (2014), quoting Commonwealth v. Silva, 440

Mass. 772, 778 (2004). "[T]he 'reasonable belief' standard is

'less exacting than probable cause.'" Gentile, supra, quoting

Silva, supra at 776-777. To be reasonable, a belief "must be

supported by specific articulable facts that, based on the

3 totality of circumstances, permit a reasonable inference" that a

matter is true (quotation and citation omitted). Gentile, supra

at 822.

Here, the judge found that police had a reasonable belief

that the defendant lived at the address. The Rhode Island

warrant listed it as the defendant's last known address, and the

RISP informed the MSP that "we have placed him at this address

several times." Although the MSP lieutenant did not know the

details of the RISP investigation, the judge interpreted the

RISP statement to mean that the RISP had observed the defendant

at the address several times, and we cannot say this inference

was unreasonable. The MSP's RMV record check separately

confirmed that the defendant listed the address as his

residence.

Although the defendant argues that a reasonable belief

cannot be based on hearsay alone, he cites no authority

supporting that proposition, and Gentile is to the contrary. 1

The defendant's further suggestion that the information provided

1 In Gentile, a trooper saw the defendant's Massachusetts identification card listing an apartment address in Leominster, and the trooper confirmed that the address matched what was listed on the defendant's driver's license. Gentile, 466 Mass. at 821. The court stated, "[t]he defendant correctly does not challenge the judge's finding that the officers had a reasonable belief that the defendant resided at the apartment." Id. at 822.

4 by the RISP was akin to an uncorroborated informant's tip, is

inconsistent with Commonwealth v. Castillo-Martinez, 104 Mass.

App. Ct. 22, 26 (2024). The MSP could reasonably rely on the

veracity of statements by the RISP, see id., which stated as the

basis of knowledge that "[w]e have placed him at this address

several times." 2 Moreover, the MSP obtained corroboration of the

address from the RMV. See Commonwealth v. Lora, 43 Mass. App.

Ct. 136, 143 (1997) (RMV address records reliable). Finally,

the lieutenant testified that, in accordance with usual practice

before executing an arrest warrant for a potentially violent

suspect, "a work-up on [the] house . . . was done, and we

expected four people in that place, possibly," including the

defendant. 3 All this together supported a reasonable belief that

the defendant lived at the address.

2 We need not address the defendant's argument that the collective knowledge doctrine does not apply. See Commonwealth v. Privette, 491 Mass. 501, 503 (2023). The Commonwealth does not rely on it here, nor did this court in Castillo-Martinez, supra.

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