Boston judge’s contempt finding against an ICE agent has sparked a legal battle that reaches the highest levels of constitutional law.
At a Glance
- Suffolk DA Kevin Hayden rejected Judge Mark Summerville’s contempt ruling against an ICE agent who arrested a defendant during trial
- The case centers on Wilson Martell-Lebron, arrested by ICE during his trial for falsifying RMV documents
- Judge Summerville dismissed Martell-Lebron’s case, citing prosecutorial misconduct
- DA Hayden argues the contempt finding violates the Supremacy Clause of the U.S. Constitution
- The case highlights ongoing tensions between state courts and federal immigration enforcement
Constitutional Showdown Between State Judge and Federal Authority
Suffolk County District Attorney Kevin Hayden has publicly rejected Boston Judge Mark Summerville’s contempt finding against an ICE agent, setting the stage for a significant legal conflict. The dispute arose when ICE Agent Brian Sullivan arrested defendant Wilson Martell-Lebron outside the courthouse during his ongoing trial for falsifying documents at the Massachusetts Registry of Motor Vehicles. Judge Summerville responded by finding the federal agent in contempt and dismissing the criminal case against Martell-Lebron with prejudice, effectively preventing future prosecution for the same charges.
The District Attorney’s office firmly opposed the judge’s actions, stating they lacked both legal and factual basis. Hayden declined to pursue criminal charges against Agent Sullivan, pointing to the Supremacy Clause of the U.S. Constitution, which establishes that federal law takes precedence over state law when conflicts arise. This constitutional principle protects federal officers acting within their authority from state prosecution, creating a significant barrier to Judge Summerville’s contempt finding.
The Case That Sparked the Controversy
The legal dispute stems from a 2020 case in which Martell-Lebron was charged with falsely applying for a license and forging an RMV document. The situation escalated dramatically on the first day of his trial when ICE agents arrested Martell-Lebron, preventing his return to court for the second day of proceedings. This absence from trial became the central point of contention between the judge and prosecutors. While Judge Summerville attributed the defendant’s absence solely to ICE’s intervention, the DA’s office countered that the judge himself contributed to this problem.
“Judge Summerville’s finding of contempt was premised upon the false conclusion that only ICE’s arrest of the defendant prevented him from being present at his trial,” Hayden wrote. “In reality, Judge Summerville himself also prevented the defendant from being present at his trial by refusing to issue a writ of habeas corpus for the defendant after he was taken into ICE custody. Therefore, the factual basis for his finding of contempt was flawed. Moreover, the Supremacy Clause of the U.S. Constitution bars this office from prosecuting Officer Sullivan for arresting the defendant pursuant to federal law,” said Kevin Hayden.
When Martell-Lebron failed to appear on the second day of trial due to being in ICE custody, prosecutors requested a writ of habeas corpus—a court order that would have directed federal authorities to produce the defendant in court. Judge Summerville denied this request, which the DA now argues made the judge partially responsible for the defendant’s absence. This denial would become a key point in Hayden’s criticism of the contempt ruling.
Legal and Procedural Challenges
The DA’s office has taken formal steps to challenge Judge Summerville’s rulings by filing a notice to appeal the dismissal of charges against Martell-Lebron. Hayden specifically contested the judge’s finding of prosecutorial misconduct, noting that the assigned prosecutors had not engaged in any improper conduct. This unusual situation places state prosecutors in the position of defending federal immigration enforcement actions while simultaneously criticizing them as “unprofessional and unnecessary.”
“Although the Commonwealth lacks a factual or legal basis to prosecute Officer Sullivan, we do not condone ICE’s conduct in this case,” Hayden wrote. “The Suffolk County District Attorney’s Office endeavors to protect the public in holding offenders accountable through ethical, fact-based prosecutions. The unprofessional and unnecessary detention of the defendant midtrial in this case undermines those important goals,” added Hayden.
In a parallel move, Hayden has requested investigations by both the Department of Justice and the Department of Homeland Security into ICE’s conduct in this case. This dual approach reflects the complex position the DA’s office finds itself in—defending constitutional principles of federal supremacy while expressing concern about the tactical decisions made by federal agents. The case illustrates the ongoing tensions between state judicial authority and federal immigration enforcement priorities.
