Commonwealth v. One (1) Check in the Amount of $480.00 for 1,600 Pieces of Wild Oysters (Crassostrea Virginica)

CourtMassachusetts Appeals Court
DecidedSeptember 26, 2025
Docket24-P-507
StatusPublished

This text of Commonwealth v. One (1) Check in the Amount of $480.00 for 1,600 Pieces of Wild Oysters (Crassostrea Virginica) (Commonwealth v. One (1) Check in the Amount of $480.00 for 1,600 Pieces of Wild Oysters (Crassostrea Virginica)) 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. One (1) Check in the Amount of $480.00 for 1,600 Pieces of Wild Oysters (Crassostrea Virginica), (Mass. Ct. App. 2025).

Opinion

APPEALS COURT

COMMONWEALTH vs. ONE (1) CHECK IN THE AMOUNT OF $480.00 FOR 1,600 PIECES OF WILD OYSTERS (CRASSOSTREA VIRGINICA)[1]

Docket: 24-P-507
Dates: March 4, 2025 – September 26, 2025
Present: Desmond, Ditkoff, & Englander, JJ.
County: Barnstable
Keywords: Shellfish. Municipal Corporations, Shellfish. Division of Marine Fisheries. Wampanoag Tribal Council. Forfeiture Proceeding. Practice, Civil, Forfeiture proceeding, Summary judgment.

      Civil action commenced in the Falmouth Division of the District Court Department on December 16, 2019.

      The case was heard by Lisa F. Edmonds, J., on motions for summary judgment.

      Jeffrey B. Loeb (Jonathan R. Loeb also present) for Cheenulka Pocknett.

      Maryanne Reynolds, Assistant Attorney General, for the Commonwealth.

      DITKOFF, J.  This case involves the civil forfeiture of wild oysters pursuant to G. L. c. 130, § 12, and G. L. c. 257, statutes that have not yet been applied in our published case law.  The Commonwealth asserts that the special, Commonwealth-favorable rules applicable to civil forfeiture of drugs apply to such civil forfeitures.  We write to dispel that notion, which is not supported by the statutory text.

      We consider whether the Commonwealth was entitled to summary judgment, applying the usual rule that the plaintiff has the burden to establish its case.  We conclude that the Commonwealth met its burden where the record showed that the fisherman affixed tags to the oysters with his commercial fisherman permit number and sold those oysters to a licensed wholesaler prohibited by law from buying oysters from anyone who was not a licensed commercial fisherman.  Accordingly, there was no genuine issue of material fact concerning the capacity in which the fisherman was acting.  The summary judgment record establishes as a matter of law that the fisherman was acting in his capacity as a commercial fisherman, and not as a Native American exercising his right to fish for sustenance.

      We also consider the fisherman's defense that the civil forfeiture was barred by the fact that, after the oysters were seized, the fisherman received a warning citation.  We conclude that an environmental police officer who has properly seized wrongly taken fish need not impose a fine or suspend the fisherman's commercial fishing license to proceed with civil forfeiture of the seized fish.  Accordingly, we affirm the order of the Appellate Division of the District Court affirming the decree of forfeiture.

      1.  Background.  The basic facts are not in dispute.  The fisherman and claimant, Cheenulka Pocknett, holds a valid commercial shellfishing permit issued by the Division of Marine Fisheries (DMF).  He is also a member of the Mashpee Wampanoag Tribe and, as such, has certain rights to fish for sustenance.  See Commonwealth v. Maxim, 429 Mass. 287, 289-292 (1999).

      On Wednesday, December 4, 2019, Pocknett and a friend took a large number of wild oysters from Green Pond in Falmouth.  Green Pond is closed to commercial fishing on Wednesdays (as well as Sundays, Mondays, and Fridays).  See Chapter 275, Article II, § 15(D) of the Code of Falmouth.[2]  See also G. L. c. 130, § 52, par. 1 (authorizing municipalities to regulate shellfish fisheries).[3]  Pocknett kept some oysters for personal consumption; the Commonwealth took no action regarding those oysters and appears to recognize Pocknett's right to take oysters for personal consumption.[4]  Pocknett placed 1,600 oysters in containers and affixed the containers with "DMF-required shellfish tags with [his] name[], [his] DMF issued permit number, as well as the date, time and location of the harvest." He then sold those oysters to Big Rock Oysters in Harwich, a licensed wholesale shellfish dealer.

      The same day, the Falmouth harbormaster contacted the Massachusetts Environmental Police to report unlawful shellfishing in Green Pond.  The next day, an environmental police officer went to Big Rock Oysters and inspected the DMF shellfish tags that stated that the oysters were taken by Pocknett from Green Pond on a Wednesday.  The officer told Big Rock Oysters that it should not have accepted those oysters.  He instructed Big Rock Oysters to sell the oysters but that the state would be seizing the proceeds.[5]  The officer then called Pocknett and orally advised him of the seizure and that he would be filing an action in libel (the term used in the statute).

      Three days later, the same officer issued Pocknett a warning citation for possession of shellfish from an area closed to commercial harvest, in violation of 322 Code Mass. Regs. § 16.09(2) (2019).[6]

      On December 16, 2019, the officer filed a complaint in libel in District Court for forfeiture of a check for $480, which appears to be the wholesale proceeds of the oysters.  Pocknett promptly appeared as a claimant and unsuccessfully moved to dismiss the complaint.  On the parties' cross motions for summary judgment, a judge of the District Court granted summary judgment to the Commonwealth and entered a decree of forfeiture.

      Pocknett filed a timely notice of appeal to the Appellate Division of the District Court.  The Appellate Division affirmed the decree.  Pocknett then filed a timely notice of appeal pursuant to G. L. c. 231, § 109.  This appeal followed.

      2.  Actions in libel.  An environmental police officer with "reasonable cause to believe, and [who] does believe, that fish taken, held, kept, possessed, transported or held for transportation or sale in violation of law" may search for such without a warrant and "seize any such fish," as well as "any boat, vessel, fish car, bag, box, locker, package, crate, any motor vehicle . . . or any other personal property used in a violation of the laws relative to marine fisheries and hold the same for forfeiture."  G. L. c. 130, § 9, par. 1.[7]  "All fish unlawfully taken, held, possessed or dealt with contrary to" the marine fishery laws or regulations, as well as "all boats, vehicles and apparatus used therein may, in addition to any or all of the penalties contained therein, be seized, libelled and forfeited to the commonwealth."  G. L. c. 130, § 12, par. 1.  In the case of uncontaminated fish, the seized fish may "be sold at private sale or public auction, and the net proceeds of such sale may be libelled in the same manner and with the same effect as if such proceeds were the property itself."  G. L. c. 130, § 12, par. 2.  The statute explicitly states that the procedures of G. L. c. 257 shall apply to such actions.  G. L. c. 130, § 12, par. 2.

      General Laws c. 257, in turn, applies to "[p]roperty which has been forfeited for an offence" where "no other provision is made."  G. L. c. 257, § 1.  Within fourteen days of the seizure, the person making the seizure must "file a libel" in either Superior Court or District Court "stating briefly the cause of the seizure without the details, and praying for a decree of forfeiture."  G. L. c. 257, § 2.  The court then issues an order of notice.  G. L. c. 257, §§ 4-5.[8]

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Bluebook (online)
Commonwealth v. One (1) Check in the Amount of $480.00 for 1,600 Pieces of Wild Oysters (Crassostrea Virginica), Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-one-1-check-in-the-amount-of-48000-for-1600-pieces-of-massappct-2025.