Commonwealth v. Kamiya Santos.

CourtMassachusetts Appeals Court
DecidedJuly 6, 2026
Docket25-P-1253
StatusUnpublished

This text of Commonwealth v. Kamiya Santos. (Commonwealth v. Kamiya Santos.) 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. Kamiya Santos., (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

25-P-1253

COMMONWEALTH

vs.

KAMIYA SANTOS.

MEMORANDUM AND ORDER PURSUANT TO RULE 23.0

After a traffic stop in the early morning hours, the

defendant was charged with various firearms violations and a

civil motor vehicle infraction. A jury convicted him of

carrying a firearm without a license (G. L. c. 269, § 10 [a]),

carrying a loaded firearm without a license (G. L. c. 269,

§ 10 [n]), defacement of a serial number on a firearm (G. L.

c. 269, § 11C), and possession of ammunition without a firearm

identification card (G. L. c. 269, § 10 [h] [1]). The defendant

raises two issues in this appeal. First, he contends that State

troopers unreasonably prolonged the length of time he spent

sitting near the stopped car, effecting an unreasonable seizure.

Second, he contends that the Supreme Judicial Court's decision in Commonwealth v. Ferrara, 496 Mass. 483, 488 (2025), requires

a judgment of acquittal on the charge of defacement of a serial

number on a firearm. We affirm.

Background. The defendant was a rear-seat passenger in a

car that was stopped on Massachusetts Avenue in Boston by a

State trooper in the early morning hours. The trooper stopped

the car after noticing that one headlight was not functioning

and then discovering that the car had failed inspection. The

driver immediately pulled over, stopping on Massachusetts Avenue

approximately two car lengths before the entrance to the South

Bay Plaza. Three people were in the car: the driver, a front-

seat passenger, and the defendant in the back seat. Seeing that

the front-seat passenger and the defendant did not have their

seatbelts fastened, the trooper asked all three for their names

and dates of birth to permit him to check their driver's license

status and issue written warnings for the failure to wear

seatbelts.

After returning to his cruiser, the trooper discovered that

none of the three had a valid driver's license. The same check

revealed that none of them had a firearm license. The trooper

returned to the car and let the driver know that none of the

three could drive the car away, but that a licensed driver could

come pick up the car. At that point, the trooper intended to

2 issue written warnings to both the defendant and the front-seat

passenger for their failure to wear a seatbelt.

The driver was unable to find someone to retrieve the car,

so the trooper returned to his cruiser to request that the car

be towed. At or around this time, two more troopers arrived and

began to assist the first trooper. The first trooper returned

to the car and told all three occupants to get out, taking their

personal belongings, and sit on the sidewalk. The second and

third trooper were in the vicinity while the first trooper began

an inventory search of the car pursuant to the State police

inventory policy, which was admitted in evidence at the

suppression hearing. The policy requires that closed and

unlocked containers be opened and examined.

After completing the inventory of the driver's side of the

car, the trooper moved to the passenger's side, where he had

already spied a plastic bag on the floor in front of the front

passenger seat. After opening the front passenger door, the

trooper bent over and saw that the plastic bag was open; inside,

the trooper saw what he believed to be the butt end of a

firearm.

The trooper returned to the three men and, saying something

about a gun, told the front-seat passenger to stand up,

instructing that the passenger be handcuffed. The defendant got

up and started running into the South Bay parking lot with the

3 second and third troopers in pursuit. The defendant fell and

the troopers caught up with him. A trooper patted him down,

found a gun in his waistband, and removed it.

Discussion. The defendant challenges the length of time he

spent sitting at the curb before the trooper found the firearm

in the passenger seat of the car. Asserting that the proper

stop of the car was a "routine traffic stop" whose duration was

bounded by reasonableness, the defendant asserts that the

trooper should have written the defendant a warning for his

seatbelt infraction before performing the inventory search. 1

In reviewing the denial of a motion to suppress, "[w]e

accept the motion judge's findings of fact unless they are

clearly erroneous . . . ." Commonwealth v. Bell, 473 Mass. 131,

138 (2015), cert. denied, 579 U.S. 906 (2016). Where, as here,

we find no clear error of fact, "our legal analysis focuses on

'the correctness of the judge's application of constitutional

principles to the facts as found.'" Commonwealth v. Depina, 456

Mass. 238, 241 (2010), quoting Commonwealth v. Scott, 440 Mass.

642, 646 (2004).

"A valid investigatory stop 'cannot last longer than

reasonably necessary to effectuate the purpose of the stop'"

1 The defendant does not challenge the lawfulness of the traffic stop, the trooper's decision to tow the car, the subsequent exit order, the inventory search, or the defendant's initial detention on the curb.

4 (quotation omitted). Commonwealth v. Tavares, 482 Mass. 694,

703 (2019), quoting Commonwealth v. Amado, 474 Mass. 147, 151

(2016). "The scope of a stop may only extend beyond its initial

purpose if the officer is confronted with facts giving rise to a

reasonable suspicion that 'further criminal conduct is afoot.'"

Tavares, supra, quoting Commonwealth v. Cordero, 477 Mass. 237,

243 (2017).

In the circumstances of this case, the trooper was not

obligated to issue the seatbelt warning before beginning the

inventory search, and the brief delay that followed, lasting

until the trooper discovered the firearm in the car, was not

unreasonable. See Commonwealth v. Moore, 54 Mass. App. Ct. 334,

340 (2002) ("ultimate touchstone of art. 14 and the Fourth

Amendment is whether a search or seizure was reasonable in the

circumstances"). The trooper reasonably asked the defendant and

his companions to sit on the curb after determining that the car

needed to be towed. As the defendant concedes, the tow required

the trooper first to conduct an inventory search, since the car

could have contained valuable or important personal property.

Although the defendant was detained on the side of the road, it

was nearly 2 A.M. and he was seated along a private parking lot

for a store that was closed at that time, thus mitigating

concerns about the effect of a public detention on the

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Related

Commonwealth v. Depina
922 N.E.2d 778 (Massachusetts Supreme Judicial Court, 2010)
Commonwealth v. Bell
39 N.E.3d 1190 (Massachusetts Supreme Judicial Court, 2015)
Commonwealth v. Amado
48 N.E.3d 414 (Massachusetts Supreme Judicial Court, 2016)
Commonwealth v. Cordero
74 N.E.3d 1282 (Massachusetts Supreme Judicial Court, 2017)
Commonwealth v. Scott
801 N.E.2d 233 (Massachusetts Supreme Judicial Court, 2004)
Commonwealth v. Catanzaro
803 N.E.2d 287 (Massachusetts Supreme Judicial Court, 2004)
Commonwealth v. Moore
765 N.E.2d 268 (Massachusetts Appeals Court, 2002)
Chace v. Curran
881 N.E.2d 792 (Massachusetts Appeals Court, 2008)
Commonwealth v. Tavares
126 N.E.3d 981 (Massachusetts Supreme Judicial Court, 2019)

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Commonwealth v. Kamiya Santos., Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-kamiya-santos-massappct-2026.