Commonwealth v. Hadley
78 Mass. App. Ct. 405
| Mass. App. Ct. | 2010Background
- Hadley and McMullen shared a Worcester County jail cell; on February 3, 2005, fellow inmates heard arguing and Hadley threatening a fight, saying he was ready to fight and asking McMullen to stay down.
- Officers observed McMullen with a bleeding lip and Hadley calm; Hadley was removed to an empty cell, and McMullen was hospitalized for a lacerated spleen and later died from complications; pre-existing medical conditions were noted.
- Hadley gave a short statement after Miranda warnings, acknowledging a push but denying kicking McMullen; he later wrote that McMullen stuck his middle finger in his eye and he pushed him, causing him to fall.
- May 28, 2008, Hadley spoke to Officer Adams about the case and related that McMullen had kicked him and that he was upset about the missing boots; motion to suppress these statements followed.
- A suppression hearing and trial occurred; the judge denied suppression of the Chabot statement and ruled Hadley’s statements to Adams were spontaneous; Hadley was convicted of involuntary manslaughter by battery and sentenced to four to seven years.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for endangerment of life | Hadley should have known his battery endangered life | Hadley lacked knowledge of McMullen’s vulnerabilities and risks | Evidence permitted a reasonable finding that Hadley knew or should have known his battery endangered life |
| Miranda waiver knowing intelligent voluntary | Hadley’s bipolar disorder undermines waiver | Waiver was knowing, intelligent, and voluntary | Waiver found knowing, intelligent, and voluntary; suppression denied |
| Admissibility of statements to Officer Adams under Sixth Amendment | Adams’s failure to advise counsel violated Hadley’s rights | Statements were spontaneous, not the product of interrogation | Statements admissible; no Sixth Amendment violation; spontaneous disclosure |
Key Cases Cited
- Commonwealth v. Latimore, 378 Mass. 671 (1979) (standard for reviewing sufficiency of evidence)
- Commonwealth v. Williams, 428 Mass. 383 (1998) (elements of involuntary manslaughter by battery)
- Commonwealth v. Hailey, 62 Mass. App. Ct. 250 (2004) (battery-endangerment framework)
- Commonwealth v. Platt, 440 Mass. 396 (2003) (endangerment or high likelihood of harm standard)
- Commonwealth v. Druce, 453 Mass. 686 (2009) (mental illness and waiver of Miranda rights)
- Commonwealth v. Zagrodny, 443 Mass. 93 (2004) (standing for knowing intelligent voluntary waiver despite mental illness)
- Commonwealth v. Bandy, 38 Mass. App. Ct. 329 (1995) (non-interrogation spontaneous statements)
- Commonwealth v. Hilton, 443 Mass. 597 (2005) (Sixth Amendment and admissibility of spontaneous statements)
- Commonwealth v. Isaiah I., 450 Mass. 818 (2008) (standards for constitutional waivers)