The Massachusetts Appeals Court today ruled that parts of an accused murderer’s statement to the police cannot be used at trial because he was not provided with his Miranda warnings. The name of the case is Commonwealth v. Pinney.
On March 23, 2014, a Springfield cop was dispatched to the defendant’s home to investigate the report of a serious assault. Upon arrival, the victim’s boyfriend told the officer that his girlfriend was inside and had been assaulted. The officer entered the house and found the defendant in a hallway. The defendant, who appeared upset, had cuts on his arms and there was blood in the kitchen and the hallway. The officer also saw knives near the kitchen sink and, concerned for his safety, he ordered the defendant to get on the ground at gunpoint. The officer asked the defendant if there was anybody else in the house and the defendant said nobody else was present. However, a second officer arrived shortly thereafter and found the victim, who was unresponsive, naked, and suffering from visible wounds, in the defendant’s bedroom. The defendant was handcuffed and remained at the scene for just under an hour. He was then driven (still handcuffed) to the police station and taken to a small interview room. More than an hour later, the cops removed the defendant’s handcuffs and two detectives began the interrogation. Before asking him questions, one of the detectives told the defendant he was not under arrest and was free to leave. The defendant was not given his Miranda rights (he had the right to remain silent; anything he said could be used against him in court; and he had the right to have an attorney present during questioning). During the interrogation, the defendant told the cops he was stressed, tired, and having a bad day. He said he and the victim had used cocaine together and he had taken 10 Lorazepam pills in an effort to harm himself. The defendant further stated he had cut his own wrists and passed out in his bedroom. He said he didn’t know how the victim came to be lying on his bedroom floor. At the end of the interrogation, the defendant was taken to the hospital to address his suicidal thoughts. When he was released from the hospital eight days later, he was arrested.
The defendant filed a motion to suppress the statement he made to the responding officer at his house (denying there was anyone else inside) and the statements he made during his interrogation at the station. The defendant argued he was entitled to receive Miranda warnings prior to being questioned. Miranda warnings are required when: the suspect is in custody; and the police are interrogating him. The Commonwealth argued the defendant was not in custody during the interrogation at the police station, pointing out that a detective explicitly told the defendant at the beginning of the interview that he was not under arrest and was free to leave. The Appeals Court disagreed, ruling that the cop’s assertion that the defendant was not under arrest was inconsistent with the facts. In determining whether a suspect was in custody, courts consider: (1) where the interrogation took place; (2) whether the cops conveyed to the person being questioned that he was a suspect; (3) the nature of the interrogation; and (4) whether the person was free to end the interview and leave. In this case, the defendant had been in handcuffs for more than two hours before the interrogation started at the police station. The detectives asked “pointed” questions of the defendant and let him know they didn’t believe he was being honest. The defendant clearly would not have been permitted to walk out of the police station. The detectives conducted a custodial interrogation of the defendant, and Miranda warnings should have been given. Therefore, the defendant’s statements at the station cannot be used against him at his upcoming trial.
The officer who responded to the defendant’s house and asked if anyone else was home was not required to provide the defendant with Miranda warnings. The Court ruled that the officer was trying to assess an emergency situation that might have posed a threat to the public safety. In that situation, a police officer is not required to pause to provide a suspect with Miranda warnings, even if the suspect is in custody. Therefore, the defendant’s (false) statement that nobody else was in his home will be admitted at his trial.