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A defendant seeking to suppress evidence based on a claim that a traffic stop violated principles of equal protection bears the burden of establishing, by motion, a reasonable inference that the officer's decision to initiate the stop was motivated by race or another protected class. To raise this inference, the defendant must point to specific facts from the totality of the circumstances surrounding the stop; the inference need not be based in statistical analysis. If this inference is established, the defendant is entitled to a hearing at which the Commonwealth would have the burden of rebutting the inference.
Two members of the Boston police department’s youth violence strike force noticed a maroon Mercedes pass in front of them on a residential street. The driver was a Black man. The officers decided to query the vehicle's license plate in their onboard computer. The results returned indicated that the vehicle was registered to a Black woman and that it lacked an inspection sticker. The officers stopped the vehicle. When they learned that the driver, the defendant, had outstanding warrants and his driver's license was suspended, they searched the vehicle and found a gun in a bag on the rear passenger seat. The defendant was charged with several firearms offenses. He moved to suppress the evidence seized from the vehicle, on the ground that the motor vehicle stop was the product of selective enforcement based on race, and the inventory search of the vehicle was impermissible. The Superior Court judge denied the defendant’s motion. The defendant appealed.
Did the Superior Court judge err in denying defendant’s motion to suppress evidence seized from the vehicle?
The court held that the Superior Court judge abused his discretion in denying defendant's motion to suppress, because defendant produced sufficient evidence to raise a reasonable inference that the stop was racially motivated. In order to ensure that drivers who were subjected to racially motivated traffic stops have a viable means by which to vindicate their rights to the equal protection of the laws under the Massachusetts Declaration of Rights, the court established a revised test under which a defendant seeking to suppress evidence based on a violation of equal protection bore the burden of establishing, by motion, a reasonable inference that the officer's decision to initiate the stop was motivated by race or another protected class. According to the court, the defendant must point to specific facts from the totality of the circumstances surrounding the stop; the inference need not be based in statistical analysis.