Commonwealth v. Hoyt, 461 Mass. 143

Hoyt was convicted of two counts of rape of a child under sixteen and two counts of indecent assault and battery on a person over fourteen.
During custodial interrogation after arrest, Hoyt, having been given Miranda warnings, stated he wanted an attorney but could not afford one, then spoke further with police without counsel present.
Hoyt signed a Miranda waiver and made inculpatory statements later suppressed by motion judge but admitted at trial.
A four-day trial with the interrogation video shown to the jury resulted in guilty verdicts on the charged counts.
Hoyt appealed asserting (i) the statements were obtained in violation of his right to counsel and that the waiver was invalid, (ii) testimony about multiple first complaints was improperly admitted, and (iii) ineffective assistance of counsel.
The Massachusetts Supreme Judicial Court reversed Hoyt’s convictions, ordered a new trial, and remanded.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Hoyt unambiguously invoked the right to counsel.	Commonwealth contends invocation was ambiguous.	Hoyt argues explicit request for attorney was clear.	Invocation was unambiguous; interrogation should have ceased.
Whether Hoyt's Miranda waiver was knowing, voluntary, and intelligent.	Commonwealth must prove valid waiver beyond a reasonable doubt.	Hoyt misunderstood his right to appointed counsel; waiver invalid.	Waiver invalid; statements suppressed.
Whether admission of the statements was harmless beyond a reasonable doubt.	Admission was harmless due to other evidence.	Erroneous admission could have affected verdict.	Erroneous admission not harmless; new trial required.
Whether first complaint testimony was improperly admitted.	First complaint testimony admissible under limited first complaint doctrine.	Multiple first complaint witnesses violated the doctrine; improper.	Subject to retrial-directed standards; requires careful limiting instructions.
Whether there was ineffective assistance of counsel.	Not argued as a standalone issue on retrial.	Potential issues but not necessary to resolve now.	Not addressed on retrial given remand.

Commonwealth v. Day, 387 Mass. 915 (Mass. 1983) (heavy burden to prove valid Miranda waiver beyond a reasonable doubt)
Edwards v. Arizona, 451 U.S. 477 (U.S. 1981) (once right to counsel invoked, interrogation must cease unless reinitiated by suspect)
Davis v. United States, 512 U.S. 452 (U.S. 1994) (heightened clarity rule for postwaiver invocations of counsel rights)
Morganti, 455 Mass. 388 (Mass. 2009) (prewaiver invocations evaluated; clarified invocation standards)
Rankins, 429 Mass. 470 (Mass. 1999) (prior decisions on invocation and waiver of rights)
Smith v. Illinois, 469 U.S. 91 (U.S. 1984) (retrospective doubt on initial request to counsel not allowed)
North Carolina v. Butler, 441 U.S. 369 (U.S. 1979) (knowing and voluntary waiver requires understanding warnings)