Commonwealth v. Baye
462 Mass. 246
| Mass. | 2012Background
- Arson-fire spree in Northampton; defendant questioned multiple times, with a 10-hour January 4, 2010 interrogation that was recorded; Miranda warnings given but no signed waiver; defendant invoked right to counsel after initial questioning; troopers used minimization, mischaracterization of law, and assurances of leniency to pressure confession; key issue is whether statements were voluntary or tainted by improper police tactics; court finds suppression appropriate and remands for further proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Custodial status when invoking counsel | Meets custodial custody indicators due to duration and accusatory tone | Was not custody when invoked or was free to leave | Custody found; invocation tainted interrogation (custodial status). |
| Voluntariness standard applied to the statements | Voluntariness shown beyond reasonable doubt | Coercive tactics undermined free will | Statements suppressed as involuntary. |
| Minimization and implied leniency promises | Promised leniency and minimized seriousness were acceptable | Promises manipulated defendant’s decision to confess | Promises and minimization contributed to coercion; suppression affirmed. |
| Assurances that statements would not be used against him | Assurances were consistent with cooperative defense | Assurances rendered statements involuntary | Such assurances rendered statements involuntary. |
Key Cases Cited
- Commonwealth v. Meehan, 377 Mass. 552 (Mass. 1979) (heavy burden to prove voluntariness; totality of circumstances)
- Commonwealth v. Novo, 442 Mass. 262 (Mass. 2004) (false promises and coercive tactics in interrogation)
- Commonwealth v. DiGiambattista, 442 Mass. 423 (Mass. 2004) (minimization and assurances of leniency can render confession involuntary)
- Commonwealth v. Tremblay, 460 Mass. 199 (Mass. 2011) (coercion analysis; limits of isolated improper conduct)
- Commonwealth v. Durand, 457 Mass. 574 (Mass. 2010) (burden to show not overborne; relevance of defendant’s characteristics)
- Commonwealth v. Hilton, 450 Mass. 173 (Mass. 2007) (custodial status and interrogation strategy; pre- and post-warning considerations)
- Edwards v. Arizona, 451 U.S. 477 (U.S. 1981) (right to counsel; interruption of interrogation after request)
- Dickerson v. United States, 530 U.S. 428 (U.S. 2000) (standard for voluntariness and Miranda procedures)