The Massachusetts Supreme Judicial Court today upheld the murder conviction of a man who killed his girlfriend’s mother by lighting her on fire. The name of the case is Commonwealth v. Bell.
The defendant was indicted for a number of crimes, including murder and arson, for an incident that occurred in January of 2007. The defendant had been dating the victim’s daughter, but they had a volatile relationship that caused the daughter to obtain a restraining order against him. The victim, her daughter, and several other family members lived together in Springfield and the defendant lived in a nearby apartment building.
During the evening of January 7, 2007, the defendant tried to get in touch with the victim’s daughter, but she ignored his calls. The defendant went to the victim’s house, broke in, and walked into the kitchen where the victim and other members of the family were standing. The victim’s relatives testified that the defendant was holding a bottle from which he was squirting liquid. Several of the family members ran into one of the bedrooms. They realized the victim had been left behind when they heard her scream. When they exited the bedroom, they saw the defendant, with his leg on fire, attempting to unlock the front door. He was eventually able to open the door and leave. Meanwhile, the victim was engulfed in flames. It took several moments for the family members to extinguish the fire and by then, the victim had sustained serious burns over 90% of her body. She died several weeks later from complications related to her burns.
When the police arrived at the scene, the victim’s relatives told the officers the defendant had started the fire and pointed in the direction in which he had walked. The police found the defendant a short distance away and he repeatedly said he had started the fire. The officers observed serious burn injuries on the defendant’s body. He was walking gingerly and appeared to be in pain. The police arrested the defendant and searched his pockets. One of the officers found a book of matches and the defendant said that’s what he had used to start the fire. The officers read the defendant his Miranda warnings and told him to stop talking. However, the defendant continued to make admissions and also said repeatedly that he was badly burned and in pain.
The defendant’s story was that he was locked out of his apartment on the night of the murder. He called the victim’s daughter, who invited him over to pick up her set of keys to his apartment. The defendant went to the victim’s house and rang the doorbell, but nobody answered. The defendant started to smoke a cigarette and banged on a window next to the door, causing it to break. He entered the apartment and was confronted by the victim, who threw gasoline in his face. The defendant’s cigarette ignited the gasoline and the fire spread to the victim’s nightgown. The defendant fled the house, passed out on the grass, and awoke to police officers standing over him. He denied confessing to the crime. The jury convicted the defendant of murder and he appealed.
The central issue on appeal was whether the defendant’s statements to the police should have been admitted against him at trial. Defendants can seek to suppress their statements under two distinct legal theories. The first is that the police did not properly advise the defendant of his Miranda warnings. Miranda warnings are required only when the police are conducting a custodial interrogation. If a defendant is (1) not in custody, or (2) not being interrogated, he is not entitled to receive his Miranda warnings. In this case, because the defendant’s statements were made spontaneously and not in response to police officers’ questions, he was not entitled to receive Miranda warnings.
However, a defendant can also move to suppress his statements if they were not voluntary – that is, the statements were not the product of free will and rational intellect. The defendant argued that a number of factors, including his inhalation of toxic fumes, his consumption of alcohol, and his severe pain from the burn injuries rendered him unable to make a voluntary statement. A superior court judge denied the defendant’s motion and the Supreme Judicial Court affirmed. While alcohol consumption and physical pain are factors to consider in determining whether a statement is voluntary, the Court found here that the totality of the circumstances established that the defendant was speaking freely. The Court pointed out that the defendant was coherent, appropriately answered the police officers’ questions, understood that the victim was seriously injured, and tried to get help for the victim. His statements to the police indicted he knew what was happening and voluntarily chose to speak to the officers.
As always, it is never smart for a suspect to talk to the police about a crime. If the defendant here had kept his mouth shut, the case against him would not have been nearly as strong.