The Massachusetts Supreme Judicial Court today affirmed a Lawrence man’s convictions for murdering his wife and her two teenage children in 2011. The name of the case is Commonwealth v. Tejada.
On September 4, 2011, the defendant approached his neighbor in a parking lot at approximately 2:00 a.m. and said he had just killed three people. The neighbor, who did not know the defendant, called the police and officers responded shortly thereafter. The defendant told the neighbor his family had been “talking down to him,” which resulted in the killings. When the cops arrived, they had the defendant sit on a curb and asked him what happened. The defendant said his family would not stop yelling at him, so he shot them. He then tried to shoot himself but he had run out of bullets. He left the victims’ apartment, got rid of the gun, and confessed to his neighbor. After telling his story, the defendant was handcuffed while the police went to the apartment to investigate. When nobody answered the door, the police broke in and found the three victims, all dead from gunshot wounds. Officers saw bloody footprints on the stairs and in the kitchen and a forensic expert at trial testified the footprints were consistent with the shoes the defendant had worn on the night of the murders. The defendant’s hands tested positive for gunshot residue and the victims’ blood was discovered on his clothes. Behind the victims’ apartment building, the police found a revolver that turned out to be the murder weapon, and it had traces of one of the victim’s DNA. An Essex superior court jury found the defendant guilty of three counts of first-degree murder.
On appeal, the defendant argued his confession to the police should have been suppressed because he was not read his Miranda rights prior to making the statement. The Supreme Judicial Court reviewed the familiar rule that Miranda warnings are required only when a defendant is in custody and subject to police interrogation. The question here was whether the defendant was in custody during his conversation with the police officers. In determining whether a suspect was in custody, courts consider: (1) where the interrogation took place; (2) whether the cops told the suspect he was suspected of committing a crime; (3) the tone of the interview and the level of aggressiveness exhibited by the interrogating police officers; and (4) whether the the suspect was free to leave. In this case, the Court concluded application of the first three factors suggested the defendant was not in custody. The questioning took place in a pubic parking lot (as opposed to a police interrogation room at the station), the defendant was not handcuffed, and there was no evidence the defendant was intimidated by the police. While it is true the defendant was not free to leave, this fact alone is not dispositive on the question of custody. Because the defendant was not in custody at the time he confessed to the police, he was not entitled to Miranda warnings and his statement was properly admitted at trial.
The SJC also ruled the evidence was sufficient as a matter of law to support the convictions for first-degree murder. The defendant will now spend the rest of his life in state prison.