Commonwealth v. Walker
466 Mass. 268
| Mass. | 2013Background
- Stevie Walker convicted of first-degree murder on extreme atrocity/cruelty theory (Dec 19, 2007).
- Defendant moved to suppress statements; motion denied with one irrelevant exception.
- Suppression hearing: Nov 4–6, 2005; statements given after Miranda warnings; six-hour interview recorded; argued Miranda waiver and voluntary intoxication, Rosario delay, and right to a telephone call.
- DNA evidence linked defendant to the crime scene (blood on shirt; blood on curtain; dreadlock matched).
- Defense experts diagnosed paranoid/sch schizoid traits; defense contended lack of intent due to mental condition and cocaine use; Commonwealth argued voluntary waiver and admissibility of statements.
- Trial judge instructed jurors to consider mental impairment and voluntary drug use in connection with Cunneen factors and extreme atrocity/cruelty; Model Instructions revised in 2013; Rosario issues discussed but rejected; no relief under c. 278, §33E.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Miranda waiver voluntary beyond reasonable doubt | Walker knowingly and intelligently waived Miranda rights | Walker was in a debilitated state affecting voluntariness | Waiver voluntary beyond reasonable doubt |
| Voluntariness of statements separate from Miranda waiver | Statements were voluntary under totality of circumstances | Will was overborne by condition or interrogation | Statements voluntary; no reversal |
| Delay/Rosario violation and admissibility | Failure to arraign within six hours could trigger suppression | Rosario violation; delay coercive | No Rosario violation; no suppression; delay not coercive |
| Jury instructions on Cunneen factors and mental impairment | Instructions adequately covered Cunneen factors for extreme atrocity/cruelty | Instructions inadequate; misapplied Cunneen | Instructions adequate; Cunneen addressed; no reversible error |
Key Cases Cited
- Commonwealth v. LeBeau, 451 Mass. 244 (Mass. 2008) (beyond reasonable doubt standard for waiver and voluntariness)
- Commonwealth v. Bins, 465 Mass. 348 (Mass. 2013) (waiver and voluntariness of statements; totality of circumstances)
- Commonwealth v. Medeiros, 395 Mass. 336 (Mass. 1985) (distinct inquiries; totality of circumstances in voluntariness)
- Commonwealth v. Mandile, 397 Mass. 410 (Mass. 1986) (factors for voluntariness and Miranda waiver; age, education, experience)
- Commonwealth v. Tolan, 453 Mass. 634 (Mass. 2009) (totality of circumstances; testing voluntariness)
- Commonwealth v. Cunneen, 389 Mass. 216 (Mass. 1983) ( Cunneen factors for evaluating extreme atrocity/cruelty evidence)
- Commonwealth v. Szlachta, 463 Mass. 37 (Mass. 2012) (rejection of narrow Cunneen-related interpretation of instructions)
- Commonwealth v. LeBlanc, 433 Mass. 549 (Mass. 2001) (intoxication considerations in Miranda waiver)