The Massachusetts Supreme Judicial Court today reversed a defendant’s convictions for serious crimes because Worcester police officers used coercive and unconstitutional techniques to obtain a confession from him. The name of the case is Commonwealth v. Monroe.
The defendant was convicted of multiple counts of armed robbery, assault and battery with a dangerous weapon, indecent assault and battery, and kidnapping following a series of events in October of 2010. The case involved three alleged victims. On October 19th, a 17-year-old girl was walking to her bus stop when the defendant approached her and began asking questions. He then held a knife to her throat and ordered her to accompany him across the street. As the victim struggled, her backpack fell off her body and the defendant took it and ran away. Approximately one week later, the defendant approached a 15-year-old girl who was walking to school. The defendant held a knife to her throat and a struggle ensued. The girl was able to escape from the defendant’s grasp and ran home. Two days after that, the defendant approached a 16-year-old girl who was walking to school. He directed her to walk into a nearby building where he held a knife to her throat and allegedly sexually assaulted her. The defendant was charged with raping the girl but was acquitted at trial.
Worcester police officers arrested the defendant on the date of the third alleged attack. The defendant was transported to the Worcester Police Department and was interrogated by two detectives. The defendant waived his Miranda rights and agreed to make a statement. After obtaining some biographical information from the defendant, the detectives told him that he had been positively identified by all three alleged victims. The interview grew aggressive and the cops told the defendant that he had only “one opportunity” to tell his side of the story. The defendant told the detectives, among other things, that he had emigrated to the United States from Africa, he had mental health problems, and he had not showered or eaten recently. The detectives then began talking about the defendant’s two-month-old daughter. They suggested that the defendant’s girlfriend would lose custody of his daughter because of the defendant’s actions. One of the detectives lied and told the defendant that his DNA had been found on one of the alleged victims. The defendant broke down and told the detectives he would make a statement “on behalf of [his] daughter” because he loved his daughter. He then made several inculpatory statements.
The defendant filed a motion to suppress his statements to the police, arguing that they were not voluntarily made. A superior court judge denied the motion to suppress. Following his conviction, the defendant appealed and the Supreme Judicial Court reversed, finding that his statements were not voluntary.
Any statements by a criminal defendant must be voluntarily made in order to be admitted at his or her trial. A voluntary statement is one made of free will and not influenced by psychological or physical coercion. In this case, the SJC concluded that the Worcester detectives’ interrogation of the defendant, which included threats regarding the defendant’s ability to have contact with his daughter, was psychologically coercive. The cops falsely told the defendant that if he did not tell his story, his daughter could be removed from his girlfriend’s custody and raised by strangers. Based on the outrageous police conduct, the Court ruled that the defendant’s will was overborne. The Court also considered that the defendant was emotionally disturbed during his interrogation, the fact that he was only 18 years old, and the fact that he had emigrated from Africa only six years beforehand. Finally, the Court pointed out that the tone of the interrogation was hostile and the defendant often had no chance to respond to the rapid fire questions from the detectives. The Court reversed the defendant’s convictions and remanded the case to the superior court for a new trial.
The sleazy police behavior in this case was completely unnecessary. The case against the defendant was strong, with three alleged victims identifying him as their attacker. But because of the overzealous conduct of two Worcester detectives in interrogating the defendant, he will have a second opportunity to convince a jury that he should be acquitted of the charges against him.