Commonwealth v. Ralph Brown

CourtMassachusetts Supreme Judicial Court
DecidedJuly 10, 2025
DocketSJC-13487
StatusPublished

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

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Commonwealth v. Ralph Brown, (Mass. 2025).

Opinion

SUPREME JUDICIAL COURT

COMMONWEALTH vs. RALPH BROWN

Docket: SJC-13487
Dates: March 7, 2025 - July 10, 2025
Present: Budd, C.J., Kafker, Wendlandt, Georges, & Wolohojian, JJ.
County: Suffolk
Keywords: Homicide. Practice, Criminal, Motion to suppress, Warrant, Affidavit, Presumptions and burden of proof, Argument by prosecutor, Grand jury proceedings, Empanelment of jury, Examination of jurors, Capital case. Evidence, Argument by prosecutor, Grand jury proceedings. Search and Seizure, Warrant, Affidavit. Cellular Telephone. Grand Jury. Constitutional Law, Impartial tribunal. Firearms.

      Indictments found and returned in the Superior Court Department on March 26, 2018.

      Pretrial motions to suppress evidence were heard by Elaine M. Buckley, J., and the cases were tried before James F. Lang, J.

      Richard P. Heartquist for the defendant.

      Brooke Hartley, Assistant District Attorney, for the Commonwealth.

      BUDD, C.J.  In the daytime hours of January 11, 2018, the victim, Shaquille Browder, was shot and killed in the parking lot of a fast food restaurant in the Dorchester section of Boston.  The defendant, Ralph Brown, was indicted and convicted of murder in the first degree on a theory of deliberate premeditation.[1]  On appeal, the defendant claims that various errors committed by judges who heard his pretrial motions, the trial judge, and the prosecutor require us to vacate his conviction and order a new trial.  He also argues that his conviction must be vacated because the Commonwealth failed to introduce sufficient evidence of his guilt.  After careful review, we affirm the defendant's conviction of murder in the first degree and decline to grant extraordinary relief pursuant to G. L. c. 278, § 33E.

      Background.  We summarize the facts as the jury could have found them, reserving certain details for later discussion. 

      On January 11, 2018, the victim drove two friends to a fast food restaurant and backed into a spot in the parking lot.  Two motor vehicles, a black sport utility vehicle (SUV) and a white U-Haul pickup truck, each containing a driver and a passenger, had been tailing the victim's car for approximately eight minutes and followed the vehicle into the lot.  As the victim and his friends sat in the car, a man got out of the SUV from the passenger's side, walked to the rear of the victim's car, and began firing a gun at the victim and his friends.  The victim's back seat passenger crouched on the floor of the car and avoided harm.  The victim and the front seat passenger fled from the car and ran away from the shooter in the direction of the pickup truck, which was positioned facing the victim's car.  As they did so, both occupants of the pickup truck opened fire.  After the shooting, the pickup truck and the SUV sped away.  The passenger had been shot in the shoulder but survived; the victim had been shot in the chest and later died from his injuries.

      Using surveillance footage, police were able to identify both vehicles as rentals, and later recovered the pickup truck and the black SUV from their respective rental centers.  Police investigation further revealed that the codefendant, Kyle Gathers,[2] had rented the black SUV, a Chevrolet Tahoe, and the defendant had rented the pickup truck.  Cell phone records indicated that there were numerous calls between the defendant's cell phone number, the same number he listed on the U-Haul rental agreement, and Gathers's cell phone on the day of the shooting, including a twenty-two minute telephone call that ended two minutes after the shooting.  Cell site location information (CSLI) showed the defendant's cell phone connected to cell towers close to the location of the murder around the same time as the murder, as well as cell towers near the U-Haul rental center at the time the defendant returned the pickup truck. 

      Discussion.  On appeal, the defendant argues that his motions to suppress the fruits of two search warrants wrongly were denied, and that errors before the grand jury, during voir dire, and at trial require us to reverse his conviction.  He further asserts that the Commonwealth introduced insufficient evidence of his guilt. 

      1.  Search warrants.  After the murder, Boston police Detective Richard Moriarty obtained a search warrant granting him authorization to extract data from the "infotainment" system[3] of the black Chevrolet Tahoe that Gathers used in the shooting.  Based on a search of that system, Moriarty learned that a telephone number associated with Gathers had the defendant's telephone number stored in its contact list.  The infotainment system also revealed that these numbers communicated multiple times around the time of the shooting.  With this information, Moriarty sought and was granted a search warrant for the CSLI of the defendant's cell phone.

      Moriarty's affidavits in support of the search warrants for the Tahoe's infotainment system and the CSLI of the defendant's cell phone contained passages of identical language describing the early part of the police investigation.  In each affidavit, Moriarty wrote, in part:

"Video surveillance was located by detectives.  Detectives observed on the video surveillance the victims' white Toyota Camry come into view and back into a parking spot . . . .  Closely following the white Toyota Camry is a black Chevrolet Tahoe followed by a white GMC pickup truck, which has no writing on the driver's side, but has markings on the rear and passenger's side representative of 'U-Haul.'"

In the following paragraph, Moriarty stated that still photographs derived from surveillance footage were distributed throughout the Boston police department, and that an officer on an unrelated assignment at a rental car agency located one of the suspected vehicles, a black Chevrolet Tahoe, by matching the license plate to the SUV observed in the surveillance footage. 

      The defendant moved to suppress data extracted from the infotainment system of the Tahoe and data obtained from the CSLI of his cell phone arguing that, among other things, the affiant misrepresented the sequence of the investigation.  See Franks v. Delaware, 438 U.S. 154 (1978).  After a two-day evidentiary hearing, which included testimony from Moriarty and two other members of the Boston police department,[4] a Superior Court judge (first motion judge) denied the defendant's motions, concluding that although Moriarty could have taken more care in writing the affidavits, there were neither material misstatements of fact nor an "intent[ion] to deceive for the purposes of a finding of probable cause."

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Commonwealth v. Ralph Brown, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-ralph-brown-mass-2025.