Earlier this month, a state appellate court issued a written opinion in a Massachusetts drug trafficking case discussing whether the evidence seized by the police was done so in violation of the defendants’ constitutional rights. Specifically, the court had to determine if the defendants should have been provided with Miranda warnings prior to being asked questions by police. Ultimately, the court concluded that, although the defendants were not free to leave, they were not “in custody” for the purposes of the Miranda analysis.
The Facts of the Case
A police officer was walking into a store when he heard one of the defendants on the phone. The officer believed that the defendant was arranging a narcotics transaction, and he began to follow the defendant. The defendant ultimately met up with another man, and the two engaged in a transaction of unknown objects. This confirmed the officer’s suspicions, and he called back-up.
The officers approached the two defendants and separated them immediately. One of the officers claimed to have given one of the defendants some version of the Miranda warnings, but the officer was unable to recall exactly what was stated to the defendant. The other defendant was not read any of his Miranda rights.
Both defendants made inculpatory statements, which led to a search of the defendants’ vehicles and the discovery of narcotics. The defendants filed a motion to suppress the evidence, arguing that it was only recovered based on the officers’ impermissible custodial interrogation.
The trial court initially granted in part each of the defendants’ motions, and the prosecution appealed.
The Appellate Court’s Decision
On appeal, the case was reversed, with the court finding that neither of the defendants’ motions should have been granted. The court explained that Miranda warnings are required as soon as a defendant is subject to “custodial interrogation.” When determining if a police interaction raises to the level of a custodial interrogation, courts consider several factors, including:
- The place of the interrogation,
- Whether the officers explained to the defendants that they were suspects,
- The nature and tone of the interrogation, and
- Whether, at the time the statement was made, the defendants were free to leave.
After taking each of the factors into account, the court held that the defendants were not subject to custodial interrogation, and it reversed the lower court’s finding to the contrary. In so holding, the court acknowledged that the defendants were not free to leave, but it held that the remaining factors counseled against a finding of custodial interrogation.
Have You Been Arrested for a Boston Drug Crime?
If you have recently been arrested for a Boston drug crime, you should contact the Law Office of Patrick J. Murphy. Attorney Murphy has over 22 years of experience handling Boston drug trafficking cases, and he knows what it takes to succeed on his clients’ behalf. Through diligent investigation, thorough preparation, and zealous advocacy, Attorney Murphy puts the interests of his clients at the forefront. To learn more, and to schedule a free consultation with Attorney Murphy, call 617-367-0450.
More Blog Posts:
Massachusetts Appellate Court Denies Defendant’s Motion to Suppress Based on Allegedly Illegal Stop-and-Frisk, Boston Criminal Defense Lawyer Blog, published May 16, 2018
Massachusetts Court Grants Motion to Suppress Based on Officer’s Prolonged Traffic Stop, Boston Criminal Defense Lawyer Blog, published April 24, 2018