Commonwealth v. Monroe, 472 Mass. 461

Monroe was eighteen at the time of the October 2010 attacks on three teenage girls in Massachusetts.
The incidents involved assault and battery with a knife, armed robbery, kidnapping, and indecent assault; DNA linked Monroe to at least one victim.
A videotaped postarrest interrogation began after Monroe was read Miranda rights and waived them; the detectives repeatedly pressured Monroe using his child’s custody implications.
During the interview, detectives explicitly warned of potential removal of Monroe’s child and repeatedly referenced the child’s welfare and custody, interjecting emotional pleas.
Monroe showed emotional distress, cried, and was largely unresponsive until the custodial threats intensified, after which he made incriminating statements.
The incriminating statements were admitted at trial via the detectives’ testimony and a redacted videotape, forming pivotal evidence for the prosecutions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Were Monroe's postarrest statements involuntary?	Commonwealth argues no coercion; statements voluntary.	Monroe contends coercive psychological tactics, especially about his child, overbore his will.	Yes, statements involuntary due to coercive custodial threats.
Did admission of the involuntary statements violate due process?	Admitting statements did not violate due process if properly weighed.	The involuntary statements violated Monroe's constitutional rights and should not have been admitted.	Yes, admission violated due process.
Was the error harmless beyond a reasonable doubt?	Video and other evidence sufficiently linked Monroe to offenses; error harmless.	Erroneous admission significantly prejudiced the trial and was not harmless.	No; the error was not harmless beyond a reasonable doubt.

Commonwealth v. Tremblay, 460 Mass. 199 (Mass. 2011) (voluntariness framework for confessions)
Commonwealth v. LeBlanc, 433 Mass. 549 (Mass. 2001) (factors in totality of circumstances)
Commonwealth v. Baye, 462 Mass. 246 (Mass. 2012) (coercive tactics and voluntariness burden)
Commonwealth v. Selby, 420 Mass. 656 (Mass. 1995) (totality of circumstances and coercion factors)
Commonwealth v. Durand, 457 Mass. 574 (Mass. 2010) (analysis of harmless error and voluntariness interaction)
Commonwealth v. Magee, 423 Mass. 381 (Mass. 1996) (emotional distress as a factor in voluntariness)
Commonwealth v. Vazquez, 387 Mass. 96 (Mass. 1982) (exculpatory statements and coercion considerations)
Commonwealth v. Santos, 463 Mass. 273 (Mass. 2012) (Santos factors for evaluating harmless error)