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Commonwealth v. Runyan

Massachusetts Supreme Judicial Court

922 N.E.2d 794 (2010)

Facts

Police responded to a complaint that someone was firing a BB gun at a home from the window of a neighboring home. When officers arrived at the scene, they found that the BB gun shooter was an 18-year-old male with developmental disabilities. When they asked the young man if there were any other guns in the home, he showed them two firearms owned by his father, Richard Runyan (defendant). One of the firearms was secured with a trigger lock; the other was unsecured. Runyan was charged with violation of a Massachusetts statute that required firearms to be locked or otherwise inoperable when not under the control of their owner. Runyan moved for dismissal. The trial judge granted the motion, applying the Second Amendment to the United States Constitution to the state as a substantive-due-process right and citing District of Columbia v. Heller, 554 U.S. 570 (2008) as controlling authority. In Heller, the United States Supreme Court invalidated a law that required handguns kept in the home to be inoperable at all times. The commonwealth (plaintiff) applied for directed appellate review, which was granted by the Massachusetts Supreme Judicial Court.

Rule of Law

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Issue

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Holding and Reasoning (Gants, J.)

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A "yes" or "no" answer to the question framed in the issue section;
A summary of the majority or plurality opinion, using the CREAC method; and
The procedural disposition (e.g., reversed and remanded, affirmed, etc.).

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