In a November 4, 2026 summary decision, the Massachusetts Appeals Court affirmed a lower-court order suppressing evidence of an unloaded firearm found during a traffic stop in Roxbury. The case, Commonwealth v. Jakeem B. Hanson-Sturrup (25-P-1057), turns on whether Boston police properly impounded a vehicle before conducting an inventory search.
Early on February 14, 2020, officers stopped a Jeep on Quincy Street after a registration check showed it lacked an inspection sticker. The defendant was driving; his girlfriend was a passenger; the vehicle belonged to his sister. After learning the defendant had a default warrant, officers ordered him out, pat-frisked him, and found nothing. The officer then decided to tow the Jeep for the missing sticker and search it where it sat (still in the travel lane).
During the search, police found an unloaded firearm in the glove compartment. The defendant’s subsequent statements were also suppressed as fruit of the poisonous tree. The motion judge relied on Commonwealth v. Lek.
The Appeals Court (Rubin, Hand & Smyth, JJ.) agreed the inventory search was unlawful, though for slightly different reasons. Impoundment must serve a legitimate noninvestigative purpose and be reasonably necessary. Here, the officer never considered practical alternatives—such as whether the Jeep could still be driven under the inspection grace-period rules, or whether the validly licensed passenger could take custody of it (with the nearby owner’s permission). Police also never told the defendant they intended to impound and search the vehicle, denying him any chance to propose a lawful alternative.
Because the impoundment was not reasonably necessary, the warrantless search and the statements that flowed from it were properly suppressed. The decision is a non-precedential Rule 23.0 summary order, but it underscores how fact-specific the “reasonable necessity” standard remains for vehicle impoundments in Massachusetts.