Following a recent evidentiary hearing in Lowell District Court, a judge has ruled that Attorney Chris Spring’s client was subjected to an unconstitutional interrogation by Lowell police officers that led to the discovery of heroin. Because of the officers’ improper conduct, the judge suppressed the drugs and the assistant district attorney was forced to dismiss the case.
On October 2, 2017, detectives from the Lowell Police vice squad were patrolling the Acre neighborhood of the city. They observed the defendant speed through the neighborhood without stopping at a red light. The detectives followed the car as it pulled into a gas station and the defendant quickly walked into the store. When the defendant returned to his car to pump gas, a detective approached him and identified himself as a police officer. The defendant immediately fled, running back into the store. The detective and other members of the vice squad followed him and grabbed him inside. They asked the defendant for his license and he admitted he didn’t have one. The defendant was placed into handcuffs, and the detectives realized they had previously identified him as a player in the city drug scene. One of the detectives asked the defendant if he had hidden drugs in the store. The defendant denied the allegation and told the detectives he was coming from his daughter’s school. When the detectives accused the defendant of being untruthful, he admitted he had recently purchased a bag of crack cocaine and was smoking it in the car. The detectives then searched his car and found a bag of heroin under the driver’s floor mat.
The defendant hired Attorney Spring, who filed a motion to suppress the heroin. Attorney Spring argued that the police had improperly interrogated his client, which led to the discovery of the drugs. The problem with the detectives’ conduct was they did not advise the defendant of his Miranda rights. Miranda is required when police officers are asking questions to a person who is in custody. In this case, as soon as the officers placed handcuffs on the defendant, he was in police custody. Therefore, the officers should not have asked him any questions, including questions about his drug use, without telling him he had the right to remain silent and the right to have an attorney present during any interrogation. The prosecutor argued Miranda warnings were not required in this case. The prosecutor relied on a 1984 U.S. Supreme Court case called New York v. Quarles that carved out a public safety exception to the Miranda requirement. In Quarles, the defendant was chased into a grocery story by a police officer who believed the defendant was carrying a gun. The cop grabbed the defendant, arrested him, and found an empty shoulder holster. He asked where the gun was and the defendant pointed toward a nearby empty carton that contained the weapon. The Supreme Court held that Miranda warnings were not required because public safety was more important than telling the suspect he had the right to remain silent. In this case, the prosecutor argued the same rule should be applied to situations where a police officer believes a suspect has discarded drugs. Ultimately, the judge disagreed and concluded the defendant was entitled to receive his Miranda warnings. Because the unconstitutionally-obtained statement led to the officers searching the defendant’s car (and discovering the heroin) the judge ruled the heroin should be suppressed as “fruit of the poisonous tree.”
As a result of the suppression order, the Commonwealth no longer had sufficient evidence to prosecute the defendant.