Supreme Judicial Court (June 11, 2008)
The reference to "corporation" in the charge of making false entries in corporate books, in violation of G.L. c. 266, § 67, encompasses all entities defined as corporations, rather than only private corporations.
The Superior Court reported the question: "May the Commonwealth prosecute a defendant under G.L. c. 266, § 67, for his falsification of Massport records?" The Superior Court's primary issue was whether Massport may be considered a "corporation." The SJC granted direct review, and it answered the question in the affirmative.
Section 67 does not define the term "corporation." In reviewing various dictionary definitions of "corporation," the SJC determined that the common usage of the term is not restrictive to private entities, and it includes "all types of corporations, without regard to the corporation's status as private or public, profit or nonprofit, or business or charitable entity." Therefore, for purposes of a section 67 violation, Massport is considered a corporation, and the defendant may be prosecuted for a section 67 violation.