The Massachusetts Supreme Judicial Court today affirmed the first-degree murder convictions against a drug-addicted Lynn man who slit the throats of his mother and grandmother in 2012. The name of the case is Commonwealth v. Wright.
The facts of this case are particularly gruesome. The defendant, who was 23 at the time of the killings, was living with his mother and grandmother in a multi-family home in Lynn. His mother had been largely absent from his life when he was growing up because her drug problems resulted in her frequent incarceration in Florida. When the defendant was a teenager, his mother moved back to Massachusetts and they reconnected, often using drugs together. It was a continuation of the defendant’s long history of substance abuse: he started smoking marijuana when he was 10 years old; began drinking hard alcohol at 13; and eventually graduated to using mushrooms, Ecstasy; cocaine, crack; heroin; and prescription medication. By the time the defendant and his mother began living together, he was a full-fledged drug addict. At some point, he began hearing voices in his head telling him to kill his mother. He retrieved a knife from the kitchen, walked into his mother’s bedroom, and slashed her throat as she slept, watching her bleed out. He then walked downstairs to his grandmother’s apartment. Paranoid that his grandmother was going to report him to the police, the defendant slashed her throat, killing her as well. The following morning, the defendant woke up and remembered he had murdered his mother and grandmother. He panicked, consumed more drugs and alcohol, dumped the bodies at a nearby elementary school, and decided to flee to Canada.
When he illegally crossed the Canadian border, the defendant was detained by Canadian law enforcement personnel. He was ordered to disrobe, as his clothes were stained with blood that the Canadian officials wanted to preserve. The defendant was then taken to an interview room where he was repeatedly advised he did not need to make a statement, he was entitled to consult with a member of the United States government (pursuant to the Vienna Convention), and he was entitled to speak to an attorney. Further, the Canadian officials told the defendant anything he said could be used as evidence against him. The defendant responded by saying he had killed his mother and grandmother, and he then gave a series of details regarding his disposal of the bodies and the murder weapon. The defendant filed a motion to suppress his statements to the Canadian officials, claiming: (1) they were not voluntary; and (2) they were given without the benefit of Miranda warnings. The trial judge denied the motion and the Supreme Judicial Court affirmed. The Court pointed out that when a defendant makes a statement to a foreign cop, he is not entitled to receive Miranda warnings. It would be impossible for the United States to order foreign law enforcement agents to provide a warning unique to American legal jurisprudence. Therefore, a defendant’s statement to a foreign agent is admissible in an American court as long as the statement is voluntary. In this case, the SJC concluded the defendant’s statement was voluntary. There was no evidence the defendant was under the influence of drugs or alcohol and he was not threatened, intimidated, or tricked by the Canadian officials. Accordingly, the defendant’s confession to Canadian cops was properly admitted at his trial in Massachusetts.
The SJC rejected the defendant’s additional appellate arguments and upheld his convictions, which will result in the defendant spending the rest of his life in prison.