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Massachusetts Court Addresses Voluntariness of Statement in Light of Defendant’s Drug Use

Earlier this month, a state appellate court issued an opinion in a Massachusetts murder case requiring the court to determine whether the defendant’s statement to police was improperly admitted into evidence at trial. Ultimately, the court rejected the defendant’s arguments, affirmed the trial court’s decision to admit the statements, and upheld the defendant’s conviction.

The Facts of the Case

According to the court’s opinion, the defendant was arrested and charged for the murder of a drug dealer. Evidently, the defendant arranged for the victim to meet him in a parking lot, where the defendant stabbed the dealer multiple times in the chest and arm.

As it turns out, the defendant had told his girlfriend about two weeks earlier that he was considering robbing his drug dealer. He brought up his plan again to her just two days before the incident.

The police came to the defendant’s home, who agreed to go to the station to make a statement. Initially, the defendant denied all involvement. However, detectives brought the defendant’s girlfriend into the room, who told the defendant, “I already told them everything.” After this, the defendant admitted to stabbing the victim, but claimed he did so in self-defense.

The defendant’s statement was admitted into evidence and considered by the jury, which ultimately found him guilty of first-degree murder. The defendant appealed.

The Appeal

On appeal, the defendant claimed that his statement should not have been admitted into evidence because 1.) he claimed to have invoked his right to remain silent two times during the interview, and 2.) he claimed to have been under the influence of narcotics at the time he made the statement.

First, the court explained that a defendant who claims he invoked his right to remain silent must show that they “clearly and unambiguously” invoked the right. Here, the court held that was not the case. The court explained that the defendant’s statement that he was “not going to keep answering the same questions” fell short of the clear and unequivocal invocation of the right to remain silent.

Moving on, the court rejected the defendant’s claim his statement was involuntary based on his drug use. The court noted that the trial court took issue with the defense expert’s testimony that the defendant was going through heroin withdrawal when he made the statement. Thus, taking all the evidence into account, the court determined that the defendant’s statement was knowing, voluntary and intelligent, notwithstanding the defendant’s drug use.

Have You Been Arrested after Giving a Statement to Police?

If you have recently been arrested for a serious Massachusetts violent crime after making a statement to police, contact Attorney Patrick J. Murphy for immediate assistance. Attorney Murphy is a dedicated Boston criminal defense attorney with decades of experience representing clients who are facing all types of serious allegations. He has a firm grasp of the constitutional principles that determine the admissibility of evidence, and is ready to put his knowledge and experience behind you. To learn more, and to schedule a free consultation, call 617-367-0450 today.

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