Commonwealth v. Jonathan Velez.

CourtMassachusetts Appeals Court
DecidedFebruary 13, 2026
Docket24-P-0873
StatusUnpublished

This text of Commonwealth v. Jonathan Velez. (Commonwealth v. Jonathan Velez.) 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. Jonathan Velez., (Mass. Ct. App. 2026).

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-873

COMMONWEALTH

vs.

JONATHAN VELEZ.

MEMORANDUM AND ORDER PURSUANT TO RULE 23.0

Following a motor vehicle stop, the defendant was charged

with various gun and drug offenses. He later moved to suppress

evidence on the ground that the stop resulted from selective law

enforcement based on his Hispanic ethnicity. After an

evidentiary hearing, a judge of the District Court allowed the

motion. The judge later denied the Commonwealth's motion to

reconsider. The Commonwealth appealed. We vacate the order

allowing the motion to suppress evidence and remand the matter

so that the judge may clarify his factual findings and legal

conclusions in a manner consistent with this memorandum and

order. Discussion. On a motion to suppress evidence premised on

selective law enforcement, the defendant bears the initial

burden of showing a reasonable inference that a police officer's

enforcement decision was based, at least in part, on the

defendant's ethnicity. See Commonwealth v. Long, 485 Mass. 711,

723-724 (2020). This may be shown by the "totality of the

circumstances surrounding the stop," id. at 713, which may

include, as was the case here, a statistical analysis of the

involved officer's pattern of motor vehicle stops, see

Commonwealth v. Robinson-Van Rader, 492 Mass. 1, 7-8 (2023)

(report from statistician analyzing officer's stop data raised

inference of discriminatory law enforcement).

This showing entitles the defendant to an evidentiary

hearing at which it is the Commonwealth's burden to rebut the

inference that the stop was motivated by such considerations.

See Long, 485 Mass. at 726. That there was a valid basis for

the stop is not enough to rebut the inference, since ethnicity

may still have played a part in the officer's decision to stop

the defendant as opposed to others engaged in the same

violation. See Robinson-Van Rader, 492 Mass. at 23-24. Nor can

an officer's "simple denial" of ethnic motivation suffice to end

the inquiry as "implicit bias may lead an officer to make

[ethnicity-based] traffic stops without conscious awareness of

having done so." Long, supra at 734. Rather, the judge must

2 "carefully assess the officer or officers' credibility and

determine -- under the totality of the circumstances, and in

light of the factors that created the reasonable inference of

discrimination requiring an evidentiary hearing in the first

place -- whether the stop was truly made without knowledge or

consideration of [ethnicity]" (citation omitted). Commonwealth

v. Stroman, 103 Mass. App. Ct. 122, 132 (2023).

Here, the defendant moved to suppress evidence resulting

from the motor vehicle stop on a number of grounds, one of them

being selective law enforcement based on ethnicity. The matter

was scheduled for an evidentiary hearing without any prior

hearing or ruling on whether the defendant had met his initial

burden to raise a reasonable inference of discriminatory law

enforcement. Although the Commonwealth assigns error to this

procedure on appeal, it did not object below. Rather, at the

start of the evidentiary hearing, the Commonwealth "reserved the

right" to argue at the end that the defendant had not met his

initial burden. Given this acquiescence, the Commonwealth's

claim of error on this procedural point is waived. 1 See

Commonwealth v. Silva, 440 Mass. 772, 782-783 (2004) (where

defendant failed to properly alert judge of issue in trial

1 In any event, the Commonwealth does not argue that it was prejudiced in this instance, given the judge's ultimate findings, only that the procedure employed could prejudice the Commonwealth.

3 court, waiver doctrine prevented him from raising it on appeal).

As the Commonwealth does not challenge the substantive point on

appeal -- whether the judge correctly found that the defendant

had met his initial burden -- we turn to the judge's

consideration of the Commonwealth's burden at the evidentiary

hearing.

At the hearing, the Commonwealth presented the testimony of

the officer who initiated the motor vehicle stop of the

defendant, and the defendant presented the testimony and report

of his expert statistician. In his findings, the judge "greatly

credit[ed]" the testimony of both witnesses, however, we are

left with doubts regarding what specific facts were found by the

judge.

In general, the judge's findings recounted the officer's

observation, shortly after midnight, of a car in front of him

with darkened taillights and a license plate which made it

difficult to see the plate number. The findings went on to

relate that, after observing the traffic violations, the officer

followed behind the car, which made an evasive maneuver, causing

the officer to activate his blue lights and pull the car over.

The judge specifically noted that "at no time prior to stopping

the vehicle could [the officer] observe the driver." He made

further specific note that, even after the car pulled over, the

officer "still could not see the driver." After recounting the

4 facts of the motor vehicle stop, the judge found that the

officer's record of motor vehicle stops showed that he stopped

Hispanic motorists at a greater rate (42.4 percent) than his

peers at the police department (29.4 percent).

In his legal analysis, the judge stated that "the

presentation of the Commonwealth was lacking and in no way did

it rebut the reasonable inference of profiling." The remainder

of the analysis pointed out weaknesses in the expert's report

that the Commonwealth failed to challenge. The judge concluded

that "this left the court with the unrefuted testimony of [the

expert] which was enough to meet the burden set out in Long." 2

It appears that the judge may have conflated the Commonwealth's

failure to rebut the statistical data with the Commonwealth's

2 It is unclear how the judge considered the testimony of the expert to have been "unrebutted," since the judge identified a "glaring hole" in the expert's analysis and had "some serious reservations concerning the 'feeder influences' cited in [the expert's] analysis" and had "further reservations about this methodology, especially, given that Hartford is over 30 miles away."

Although the judge may have been disappointed with the Commonwealth's presentation, he was not bound to accept the expert evidence if he had a basis to doubt its credibility. See Ulin v. Polansky, 83 Mass. App. Ct.

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Related

Commonwealth v. Silva
802 N.E.2d 535 (Massachusetts Supreme Judicial Court, 2004)
Commonwealth v. Isaiah I.
861 N.E.2d 404 (Massachusetts Supreme Judicial Court, 2007)
Commonwealth v. Isaiah I.
882 N.E.2d 328 (Massachusetts Supreme Judicial Court, 2008)
Chace v. Curran
881 N.E.2d 792 (Massachusetts Appeals Court, 2008)
Ulin v. Polansky
983 N.E.2d 714 (Massachusetts Appeals Court, 2013)

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