Massachusetts court reviews warrant validity for Southbridge dual apartment search

In a pivotal court session held on April 10, 2025, in Massachusetts, judges Hand, Grant, and Wood presided over oral arguments concerning the legality of a search warrant executed at a two-family residence in Southbridge. The case centers on whether evidence obtained from the Second Floor apartment should be suppressed, as the search warrant explicitly authorized a search only of the First Floor apartment.

The Commonwealth argued for the reversal of the lower court's decision, asserting that the Second Floor apartment was effectively part of the First Floor due to the way the two units were utilized by the defendant and his family. They contended that the police had probable cause to search both apartments, as the two were treated as a single dwelling. The defense, representing the appellee Barry Hansen, countered that the two apartments were distinct and required separate warrants for searches, citing legal precedents that emphasize the importance of specificity in search warrants.

Key discussions during the hearing revolved around the configuration of the building and the nature of access between the two apartments. The Commonwealth highlighted that the defendant's girlfriend indicated both apartments were rented and used as one living space, which they argued justified the search of the Second Floor. However, the defense maintained that the physical separation of the apartments, including distinct entrances and mailboxes, underscored their independence and the necessity for a separate warrant.

Judges probed the implications of the search, questioning whether the police could have obtained a second warrant after discovering a locked door leading to the Second Floor. The defense pointed out that there was no exigent circumstance that would have prevented the police from seeking additional authorization, emphasizing that the search should remain confined to the parameters set by the original warrant.

The court's deliberations also touched on the concept of "curtilage," which refers to the area immediately surrounding a dwelling. The defense argued that the Second Floor could not be considered curtilage of the First Floor, as it was a separate apartment with its own access points. This distinction is crucial, as it affects the legal expectations of privacy and the authority of law enforcement during searches.

As the judges weigh the arguments presented, the outcome of this case could have significant implications for future search warrant applications and the interpretation of privacy rights in multi-unit dwellings. The court's decision will likely clarify the boundaries of lawful searches in similar residential contexts, potentially influencing how law enforcement approaches warrants in the future. The ruling is anticipated to be delivered in the coming weeks, leaving both parties awaiting the court's interpretation of these critical legal principles.