Commonwealth v. Runyan (2010)

By Nikki Rivas

Overview 

Commonwealth v. Runyan is a Massachusetts Supreme Court case addressing dismissal of a charge under G.L.c. § 140, § 131L (a) requiring firearms to be stored or kept in a secured or inoperable condition when outside the owner’s possession. The trial court initially dismissed the charge explaining that defendant was unable to show the provisions of the state statute legitimately infringed on his constitutional rights. On appeal, the Massachusetts Supreme Court reversed, holding that the statute’s requirement is constitutional and overall serves the safety of the general public.  

Summary 

Police officers were dispatched to a residence after report that BB pellets were being shot into a  neighbor’s window. Upon arrival, officers identified the defendant’s home as the source. However, defendant’s eighteen-year-old son, who appeared to have developmental disabilities, was the only person in the home. The son admitted to firing the shots into the neighbor’s home and stated he had done so because he hated the neighbor. Defendant’s son directed officers to his bedroom closet where the BB rifle was located and led  officers to defendant’s bedroom where there were two additional firearms under the bed. One case contained a shotgun secured with a trigger lock, while another contained an unsecured  semiautomatic hunting rifle. Defendant’s son also showed officers a dresser drawer containing easily accessible ammunition.  

Defendant was charged with violating Massachusetts’s statute G.L.c. § 140, § 131L (a) which requires firearms to be locked or secured with a safety device when not under the owner’s  immediate control. Defendant attempted to dismiss the charge arguing that the law infringed on his Second Amendment rights and was unconstitutional under Heller, which prohibits laws that render it impossible to use a firearm for self-defense in the home.  

The Massachusetts Supreme Court reversed the lower court’s decision emphasizing the statute’s constitutionality citing that the law only makes it an owner’s responsibility to keep firearms inoperable or secured when outside of the owner’s control, not if it is in the owner’s immediate possession. 

Impact 

Commonwealth v. Runyan focuses on the intersection of firearm safety and constitutional  protections. It acknowledges the risks of unsecured weapons in homes where individuals with cognitive impairments can easily gain access. The court also recognized the legitimate public safety concerns addressed by Massachusetts legislature in regulating the possession of firearms and ammunition.

Court Documents 

Commonwealth v. Runyan (2010) 

Citations 

G.L.c. § 140, § 131L (a) 

U.S. Const. amend. II  

District of Columbia v. Heller, 128 S. Ct. 2783 (2008). United States v. Cruikshank, 92 U.S. 542 (1875).