Commonwealth v. William C. Foley

CourtMassachusetts Supreme Judicial Court
DecidedJuly 15, 2025
DocketSJC-13698
StatusPublished

This text of Commonwealth v. William C. Foley (Commonwealth v. William C. Foley) 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.

Bluebook
Commonwealth v. William C. Foley, (Mass. 2025).

Opinion

SUPREME JUDICIAL COURT

COMMONWEALTH vs. WILLIAM C. FOLEY

Docket: SJC-13698
Dates: February 5, 2025 - July 15, 2025
Present: Budd, C.J., Gaziano, Kafker, Wendlandt, Georges, Dewar, & Wolohojian, JJ.
County: Norfolk
Keywords: Motor Vehicle, Citation for violation of motor vehicle law, License to operate. Practice, Criminal, Citation for violation of motor vehicle laws, Motion for a required finding. Registrar of Motor Vehicles, Revocation of license to operate. License. Statute, Construction. Words, "Reasonably necessary."

            Complaint received and sworn to in the Dedham Division of the District Court Department on February 2, 2022.

            A motion to dismiss was heard by Michael J. Pomarole, J.; a motion for reconsideration was also heard by him; and the case was heard by Paul J. McCallum, J.

            The Supreme Judicial Court granted an application for direct appellate review.

Erin R. Opperman for the defendant.

            Michael McGee, Assistant District Attorney, for the Commonwealth.

            DEWAR, J.  The defendant brings two challenges to his conviction under G. L. c. 90, § 23, third par., of operating a motor vehicle after a license revocation.

            First, the defendant contends that his motion to dismiss the complaint against him under the "no-fix" statute, G. L. c. 90C, § 2, should have been allowed.  That statute generally requires dismissal of a traffic violation if a police officer assigned to traffic enforcement duty does not issue a citation "at the time and place of the violation."  G. L. c. 90C, § 2, fifth par.  The statute contains an exception to dismissal, however, where "additional time was reasonably necessary" to investigate the violation.  Id.  Here, no citation was issued at the scene, because police did not learn of the violation until weeks later, through a television news report.  The motion judge correctly declined to dismiss the complaint because, in the circumstances of this case, additional time was indeed reasonably necessary.  See id.

            Second, the defendant challenges the sufficiency of the evidence that he operated a motor vehicle "after" a license revocation pursuant to one of the statutes listed in G. L. c. 90, § 23, third par., and "prior to the restoration of such license or right to operate."  The defendant concedes that his license was revoked for ten years pursuant to one of the listed statutes following a conviction of motor vehicle homicide, and that he had not regained his license.  He nevertheless argues that there was insufficient evidence that the instant offense took place "prior to the restoration of . . . [his] right to operate," G. L. c. 90, § 23, third par., because his ten-year revocation had expired by the time of the offense; he thus equates expiration of the ten-year revocation with "restoration" of his right to operate.  Giving effect to all the words in the statute, however, it does not apply merely during a qualifying revocation, but instead continues to apply until a defendant's license or right to operate is "restor[ed]."  Id.  Here, ample evidence showed that, notwithstanding the expiration of his ten-year revocation, the defendant's right to operate never was restored prior to this offense.  We therefore affirm.

            Background.  1.  Facts.  We first discuss the facts pertinent to the defendant's motion to dismiss.  "We adopt the [motion] judge's factual findings, which we do not disturb absent clear error, and supplement them with uncontroverted details from the record."  Commonwealth v. O'Leary, 480 Mass. 67, 67-68 (2018).

            On August 23, 2002, the defendant pleaded guilty to motor vehicle homicide by negligent operation under G. L. c. 90, § 24G (b), as appearing in St. 1982, c. 376, § 2, and to operating while under the influence of alcohol or drugs (OUI), second offense, under G. L. c. 90, § 24 (1) (a) (1).  He was sentenced to a prison term of from four years to four years and one day for the motor vehicle homicide, and to ten years of probation upon his release for the subsequent OUI offense.  At the time of these convictions, the motor vehicle homicide statute provided that the registry of motor vehicles (registry) "shall revoke the license or right to operate of a person" convicted under the statute for ten years for a first offense.  G. L. c. 90, § 24G (c), inserted by St. 1986, c. 620, § 16.[1]  The judge imposed the mandatory ten-year revocation, effective September 9, 2002.  Following the defendant's convictions, the registry additionally imposed a lifetime revocation of the defendant's license, effective September 2, 2002, under a statute applicable to persons who have a prior OUI conviction and who, in committing a subsequent such offense, cause an accident resulting in death.  See G. L. c. 90, § 24 (1) (c) (4), as appearing in St. 1982, c. 373, § 4 ("no new license shall be issued or right to operate be reinstated by the registrar" to such person).

            On November 12, 2021, an investigative journalist named Cheryl Fiandaca reported in a television news segment that the defendant had repeatedly driven a motor vehicle despite the permanent revocation of his license.  Video footage included as part of the news report depicted the defendant driving on several occasions, including on a street in Dedham.  The segment also featured footage of Fiandaca confronting the defendant, and the defendant responding by making reference to paperwork he had received from the registry.

            In mid-December, the Dedham police chief assigned Detective Michael Doyle to investigate the allegations made in the news report.  Doyle then watched the news report, in which he recognized one of the locations where the defendant was driving as a street in Dedham, and attempted to contact Fiandaca.  Doyle and Fiandaca thereafter "had phone tag back and forth," "not for any lack of trying" on either of their parts, for approximately two weeks.  The two eventually were able to speak by telephone on December 30, 2021.  Fiandaca confirmed the dates and locations of the events depicted in the footage, including that she had observed the defendant drive away from his residence in Dedham on October 29, 2021.

            By the time Doyle spoke with Fiandaca, he was aware, based on records from the registry and the Department of Criminal Justice Information Services, that the defendant's license was still revoked.  Because, however, the video footage included a statement from the defendant referring to paperwork that he had received from the registry, Doyle went to speak with the defendant at his residence on Friday, December 31, 2021, the day after Doyle's call with Fiandaca.  The defendant told Doyle that he had been attempting to regain his license but admitted that he had not yet succeeded.  On Monday, January 3, 2022, which was his next scheduled workday, Doyle wrote the defendant's citation and mailed it to him.

            2.  Procedural history.  A complaint issued against the defendant on February 2, 2022, charging him with operating a motor vehicle in violation of G. L. c. 90, § 23, third par., after his license had been revoked pursuant to the motor vehicle homicide statute, G. L. c. 90, § 24G.  He moved to dismiss the complaint under G. L.

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Commonwealth v. William C. Foley, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-william-c-foley-mass-2025.