From a “Small Item” to Major Charges: The Legal Weight of Street-Level Observations in Commonwealth v. Carattini & Mendez
In Commonwealth v. Carattini & Mendez, Nos. 24-P-331 & 24-P-335 (Mass. App. Ct. Mar. 7, 2025), the Massachusetts Appeals Court reversed a Superior Court ruling that had suppressed key evidence in a major drug and gun case. Though the ruling came in the form of a Rule 23.0 memorandum and is non-binding, it provides powerful guidance on a recurring issue in criminal law: when does a brief, seemingly innocuous street-level interaction rise to the level of probable cause?
The answer in this case? A small item, a cash exchange, a known drug hotspot, and an experienced officer were enough. The result reaffirms the principle that context and police experience matter—a lot.
Background: A Quick Exchange Sparks a Big Investigation
On a fall afternoon in 2019, Detective William Delgado of the Holyoke Police Department—an officer with 21 years on the force and deep experience in narcotics investigations—was conducting surveillance at the intersection of Lyman and Chestnut Streets. This location wasn’t just any city corner; it had recently become a focus of complaints for increased narcotics activity and was considered by police to be an “open-air market” for drug transactions.
Detective Delgado parked in an unmarked vehicle about 50–60 feet away and observed a brief exchange between an unidentified pedestrian and the driver of a white Honda Pilot. The man handed over money; the driver passed him a small object in return. The transaction was fast, and as soon as it ended, the pedestrian walked off and the Honda drove away.
Delgado believed he had just witnessed a drug sale.
The Stop and Search
Detective Delgado and his task force partners followed the Honda a few blocks and observed it park lawfully. Three officers approached the vehicle, quickly joined by two more. Delgado and another officer approached the driver—later identified as Jose Mendez—while others covered the passenger side, where Eric Carattini was seated.
Delgado immediately recognized Carattini from a prior homicide investigation and a recent social media photo of him holding a firearm. Delgado ordered both men out of the car. Mendez refused and tried to shut the door. Officers forcibly removed him, placed him on the ground, and handcuffed him. A patfrisk revealed a firearm in his front shirt pocket.
Meanwhile, Carattini cooperated, got out of the vehicle, and was also handcuffed. A subsequent search of the vehicle uncovered multiple firearms, fentanyl, heroin, oxycodone, cash, and a scale.
The Commonwealth indicted both defendants on a host of serious drug and firearm charges.
The Suppression Motion: Was It All Based on a “Hunch”?
Mendez and Carattini filed motions to suppress the physical evidence and statements made after the stop, arguing that the initial seizure was unconstitutional. Their core argument was this:
Observing an exchange of a small object for cash in a known drug area, without more, does not provide reasonable suspicion—let alone probable cause—for a stop or search.
The motion judge agreed and allowed the motions. He found that the officers lacked reasonable suspicion or probable cause when they approached and ordered the men from the car. Since the judge concluded the stop was unlawful, he did not reach the legality of the exit orders, patfrisks, or the subsequent searches.
The Commonwealth sought interlocutory review, and a single justice of the Supreme Judicial Court allowed the appeal and referred the case to the Appeals Court.
The Appeals Court: A “Small Item” Can Be a Big Deal
The Appeals Court reversed the suppression order, holding that Detective Delgado had probable cause—not just reasonable suspicion—based on the totality of circumstances.
Here’s how the court reached that conclusion.
1. Officer Experience Matters
Delgado was a seasoned narcotics officer with hundreds of drug arrests under his belt. The court emphasized that his “specialized training and experience” allowed him to reasonably interpret what he saw—not just as a random transaction, but as a drug deal.
Citing Commonwealth v. Freeman, 87 Mass. App. Ct. 448 (2015), the court reaffirmed that seasoned officers may draw inferences based on conduct that might appear ambiguous to laypeople.
2. Location, Location, Location
This wasn’t just any urban corner. The intersection was under active surveillance due to recent complaints of open-air drug dealing. Delgado wasn’t on a general patrol; he was doing targeted spot checks in a known hot zone.
The court distinguished this case from older cases like Commonwealth v. Ellis, 12 Mass. App. Ct. 476 (1981), where a similar exchange occurred in a location not known for drug activity and was observed by an officer without narcotics experience.
In contrast, the Holyoke location had specific complaints and recent activity, making the observation contextually significant.
3. The Transaction Was “Unusual” and “Furtive”
Although Delgado couldn’t see exactly what was handed over, he clearly saw a small item exchanged for money. The item was not large enough to be, say, a CD, drink, or other benign product. The court emphasized the speed of the transaction, the pedestrian’s quick exit, and the driver’s immediate departure—all consistent with street-level drug sales.
4. Comparison to Santaliz
The Appeals Court leaned heavily on the Supreme Judicial Court’s ruling in Commonwealth v. Santaliz, 413 Mass. 238 (1992), which set forth a four-part test for probable cause based on street-level exchanges:
Unusual nature of the transaction
Furtive actions of the participants
Location known for drug activity
Officer with relevant experience
All four were met in this case.
What About the Passenger? Carattini’s Fate
The court didn’t forget about Carattini. Once Mendez was lawfully stopped and Delgado recognized Carattini as someone associated with a homicide investigation and seen holding a gun in a Facebook post, an exit order for Carattini was justified.
This recognition, paired with the emerging probable cause from the search of the vehicle, gave police ample justification to detain and search him.
Implications for the Exit Orders and Patfrisks
Because the Appeals Court found that there was probable cause to arrest Mendez at the outset, it didn’t need to address whether the initial approach was a seizure, whether the exit orders were lawful, or whether the patfrisks were justified.
Probable cause short-circuits those questions: once probable cause exists, a warrantless arrest and subsequent search are permissible under the Fourth Amendment and Article 14 of the Massachusetts Declaration of Rights.
Why This Case Matters
This ruling is a valuable reminder that Massachusetts courts give substantial deference to experienced officers conducting street-level drug enforcement—especially in high-crime areas.
It also underscores the continued vitality of Santaliz, which remains a cornerstone for evaluating the constitutionality of arrests and searches based on brief public interactions.
However, this case also illustrates the fine line between a constitutionally valid inference and an unconstitutional hunch. The key differences were:
Specificity of the location (recent complaints vs. general “bad area”)
Clarity of the transaction (money for small item vs. vague interaction)
Officer's credibility and experience (seasoned narcotics detective vs. general patrol)
Practice Tips for Defense Attorneys
For defense lawyers handling drug and firearm cases with similar facts, this case offers several lessons:
1. Attack the Specificity of the Location
If the location is just a “high crime area” without recent complaints or targeted surveillance, argue that the case is closer to Ellis or Clark than Santaliz.
2. Challenge the Officer’s Observations
Was the item truly “small”? Was the transaction “furtive”? Was the exchange ambiguous? These factors matter greatly in probable cause analysis.
3. Focus on Officer Experience (or Lack Thereof)
If the observing officer is inexperienced in narcotics enforcement, the inference of a drug sale becomes weaker. The Commonwealth's reliance on police inferences should be scrutinized.
4. Preserve All Seizure and Search Arguments
Even if probable cause is claimed, build fallback arguments around the validity of the stop, exit orders, and patfrisks. Don’t concede those points too early.
Conclusion: Probable Cause Is Contextual—and Case-Specific
Commonwealth v. Carattini & Mendez doesn’t create new law, but it affirms the enduring principles behind probable cause analysis in Massachusetts:
Context matters.
Officer experience counts.
And small items, when seen through the right lens, can legally justify large consequences.
The case also reveals the careful balancing act trial courts must perform—between protecting constitutional rights and enabling effective law enforcement. For now, at least, this decision tips the scale slightly in favor of the latter.
Need help litigating a suppression motion or analyzing probable cause in your Massachusetts criminal case? Our office specializes in Fourth Amendment challenges and complex pretrial motions. Let us help you build a strong defense.