Commonwealth v. LeBlanc
Annotate this CaseAfter a jury-waived trial, Defendant was found guilty of knowingly causing damage to another automobile in a private driveway and leaving without identifying himself to the owner in violation of Mass. Gen. Laws ch. 90, 24(2)(a). The Appeals Court affirmed. Defendant appealed, arguing that the prohibition against leaving the scene without providing identification after causing property damage includes as an element of the crime that the accident causing the damage occurred on a public way. The Supreme Judicial Court affirmed, holding that the plain language of the portion of Mass. Gen. Laws ch. 90, 24(2)(a), under which Defendant was convicted, does not contain a public way element.
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