Commonwealth v. Thomas
469 Mass. 531
| Mass. | 2014Background
- Thomas set fire to a curtain inside a Brockton dwelling, causing a fatal fire and injuries to others.
- Defendant-era conviction: first-degree murder on deliberate premeditation, arson of a dwelling, and thirteen attempted murders.
- Interrogations occurred July 6–7, 2006; defendant invoked right to counsel at start of July 6 interview.
- Motion to suppress challenged July 6 and prebooking July 7 statements as Edwards/Miranda violations; postbooking July 7 confession contested.
- Trial court suppressed the July 6 and prebooking July 7 statements, admitted postbooking July 7 statements; conviction appealed on suppression/taint grounds.
- Court vacated attempted-murder convictions, affirmed arson conviction, and gave Commonwealth option to vacate murder or retry, or reduce to felony-murder in the second degree.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether July 6 and prebooking July 7 statements were properly suppressed. | Thomas argues Edwards violation; custody and taint considerations favor suppression. | Commonwealth argues no Edwards violation or taint; break in custody negates Edwards impact. | Suppression warranted for July 6 and prebooking July 7 statements under Edwards/Miranda taint. |
| Whether July 7 postbooking statements were admissible despite Edwards violation. | Postbooking statements tainted by prior Edwards violation; taint should carry. | Break in custody and later appointment of counsel disentangle taint; admissions voluntary. | Postbooking July 7 statements admissible; prebooking portions suppressed. |
| Whether the erroneous admission of suppressed statements was harmless beyond a reasonable doubt as to murder/attempted murder. | Suppressed statements could have swayed jury on intent to kill Johnson. | Evidence already supported intent; statements were cumulative. | Harmless as to arson and felony-murder; not harmless as to murder/attempted murder; Commonwealth options accordingly. |
Key Cases Cited
- Edwards v. Arizona, 451 U.S. 477 (1981) (right to counsel must be present; interrogation must cease upon invocation)
- Michigan v. Mosley, 423 U.S. 96 (1975) (police may not wear down a suspect after invocation of right to silence)
- Commonwealth v. Hoyt, 461 Mass. 143 (2011) (state taint rule; Edwards and subsequent statements in tainted custodial interrogation)
- Commonwealth v. Galford, 413 Mass. 364 (1992) (break in custody affects Edwards applicability under Federal law)