Massachusetts v. Jackson
Massachusetts Supreme Judicial Court
985 N.E.2d 853, 464 Mass. 758 (2013)
- Written by Patrick Speice, JD
Facts
Kiiyan Jackson (defendant) was arrested for distribution of a controlled substance for sharing a marijuana cigarette with two acquaintances. During the arrest, the arresting officers conducted a warrantless search of Jackson’s person and backpack, where the officers found several bags of marijuana. Before trial, Jackson moved to suppress the marijuana found during the search, arguing that the warrantless search was unlawful because the search was not conducted incident to a lawful arrest. In particular, Jackson argued that sharing a marijuana cigarette with acquaintances did not qualify as distribution of a controlled substance—the crime for which Jackson was arrested. The commonwealth argued that sharing a marijuana cigarette with acquaintances constituted unlawful distribution of a controlled substance, which gave the officers probable cause to arrest Jackson and properly conduct a warrantless search incident to a lawful arrest. The trial court denied Jackson’s motion, Jackson appealed, and the Massachusetts Supreme Judicial Court took up the appeal.
Rule of Law
Issue
Holding and Reasoning (Duffly, J.)
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