Commonwealth v. Kamal Oliver

CourtMassachusetts Superior Court
DecidedMay 23, 2025
Docket2284CR00555
StatusPublished

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

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

Opinion

SUPERIOR COURT

COMMONWEALTH v. KAMAL OLIVER

Docket: 2284CR00555
Dates: April 29, 2024
Present: William F. Bloomer Justice of the Superior Court
County: SUFFOLK
Keywords: MEMORANDUM OF DECISION AND ORDER ON DEFENDANT'S MOTION TO SUPPRESS IDENTIFICATION (Paper No. 65)

            The defendant, Kamal Oliver ("Oliver"), moves to suppress a single-photo identification of him by a civilian witness, Amiyah Chaney ("Chancy"), on August 24, 2022, during an investigation into the shooting death of Xavier I3arkon ("Barkon" or the " victim") twelve days earlier. Following a hearing, and for the reasons set forth below, Oliver's motion to suppress is

DENIED.

FINDINGS  OF FACT

            On April 9 and April 22, 2024, the court heard testimony from Chaney and Boston Police Department ("I3PD") Detective Robert Zingg ("Zingg") and received three exhibits in evidence. Oliver did not testify. The court makes the following factual findings based on the credible evidence produced at the hearing and the reasonable inferences drawn from the evidence. In making these findings, the court finds the testimony of Chaney and Zingg truthful and accurate on the relevant and material points set forth below.

            Zingg has been a I3PD officer for approximately 33 years. He has been a detective since 1998 and assigned to BPD's Homicide Unit the last twelve years. Chaney was 18 years old at the time of the incident. She was a self-taught hair stylist who cut hair at her home on a part-

                                                            -1-

time basis. J\t the time of the shooting, Chancy had three regular clients, one of whom was Oliver. Chaney knew Oliver to go by the name " Maly." Chancy also developed a personal relationship with Maly.

            On August 11 , 2022, Boston Police responded to a report of a person having been shot inside a motor vehicle parked on Oak Hill Avenue, a dead-end street in Mattapan. When police arrived at the scene, they observed that the victim, Barkon, had suffered a gunshot wound to the chest. Barkon was transported to a hospital but succumbed to his injuries the next day.

            During their investigation, detectives from the Homicide Unit, including Zingg, learned two cars were present on Oak Hill J\venue at the time of the shooting. Seated in one vehicle, blue in color, were the victim, who was the front scat passenger, and the victim's cousin, Jahmari Howard, who was the driver of the vehicle. Seated in another vehicle, a red Honda "Zip" car, were the victim's other cousin, Travin Parrara, who was the front scat passenger, and Chancy, who sat in the rear passenger compartment of the Zip car. Chancy and Travin intended to smoke marijuana. "Maly" stood outside the vehicles engaged in a heated argument with the victim.

During this argument, Chancy scrolled through Facebook on her cellphone. As she did so, she heard a gunshot. Both Chancy and Parran1 exited and ran from the red Zip car to residences on Oak Hill Avenue. As she ran to her home, Chancy observed that the victim had been shot. She neither saw Maly shoot Barkon nor did she sec Maly in possession of a firearm. By the time officers arrived, the red Zip car had left the scene.

            Zingg attempted to interview Chaney telephonically shortly after the shooting, but she left the phone off the hook and ignored him for approximately twelve minutes before hanging up on Zingg. During their investigation, Zingg and other investigators received information that the person responsible for the shooting went by the name Maly, and that this person had a Facebook

                                                            -2-

account with the username "Maly Boutabag." The prosecution subpoenaed Chancy to appear, and she did appear, before the grand jury on August 24, 2022. Sec Exhibit ("Ex.") 3 (transcript of Chaney's testimony before the grand jury). Before giving testimony, Chancy was interviewed by Zingg, BPD Sergeant Detective Scan Doherty, and the assistant district attorney. As described in greater detail below, Chaney had cut and braided Maly' s hair nearly every other week for one to two years before the shooting, and the two became friends.  During the interview, Zingg showed a single photograph of the defendant to Chancy, who confirmed that the individual depicted in the photo was "Maly." See Ex. 2. She signed and dated the photograph. The photograph depicted Oliver. During her testimony before the grand jury, Chancy again confirmed that the person depicted in the photograph was Maly. Ex. 3 at *38.[1]

            Additional factual findings are integrated in the following conclusions of law.

CONCLUSIONS  OF LAW

            Admission into evidence of an identification that was the product of an unnecessarily suggestive procedure violates a defendant's right to due process guaranteed by the Fourteenth Amendment to the United States Constitution and Article 12 of the Massachusetts Declaration of Rights. Sec generally Commonwealth v. German, 483 Mass. 553, 557-558 (2019).[2] "To succeed in suppressing evidence of such an identification, however, the defendant must prove by a preponderance of the evidence that the police procedure was ' so unnecessarily suggestive and conducive to irreparable mistaken identification as to deny [the defendant] due process of la w." ' Commonwealth v. Dew, 478 Mass. 304, 306-307 (2017).

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[1] Chancy also identified Oliver during the evidentiary hearing on April 22, 2024.

[2] Because the standard for admissibility of an identification under the Massachusetts Constitution is more favorable to a defendant than the standard under the United States Constitution, this court need not consider any federal constitutional claims. Commonwealth v. Galipeau, 93 Mass. App. Ct. 225, 227 n.3 (2018).

                                                            -3-

            "For constitutional purposes, a one-photograph identification is the equivalent of an in- person, one-on-one identification (often referred to as a 'showup')." Commonwealth v. Carlson, 92 Mass. App. Ct. 710 , 712(2018). Sec also Commonwealth v. Forte, 469 Mass. 469, 477 (2014). One-on-one identification procedures arc generally disfavored as inherently suggestive. Dew, 478 Mass. at 306. Suggestiveness alone, however, is not sufficient to render a one-on-one identification inadmissible in evidence. German, 483 Mass. at 557. Sec Commonwealth v. Silva-Santiago, 453 Mass. 782, 797 (2009) (while disfavored , one-on-one showup identifications, whether in-person or photographic, may be admissible even though they are inherently suggestive).

            "In general, a defendant may challenge a showup identification as unnecessarily suggestive in two ways. First, a defendant may attempt to show that the police did not have a good reason to conduct this type of disfavored, inherently suggestive, one-on-one identification procedure ... Second, a showup identification is unnecessarily suggestive if the procedure utilized by the police includes ' special elements of unfairness. " ' German, 483 Mass. at 558.

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Commonwealth v. Kamal Oliver, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-kamal-oliver-masssuperct-2025.