Massachusetts Supreme Judicial Court Upholds Murder Conviction in New Bedford Killing

The Massachusetts Supreme Judicial Court today affirmed a New Bedford man’s first-degree murder conviction, ruling his statement to the police had been properly admitted at trial.  The name of the case is Commonwealth v. Amaral.

On March 13, 2013, the victim’s body was found in her living room.  Her throat had been slashed and a flat screen TV had been taken from her New Bedford home.  The police reviewed her phone records and learned she and the defendant had exchanged calls shortly before the murder.  When the defendant learned the police were looking for him, he voluntarily went to the police station with his childhood friend, Michael Garcia.  The two men were separately interviewed and gave similar stories of taking the victim’s television, with her consent, to trade for crack cocaine and cash.  The defendant and Garcia told the police they smoked crack with the victim and then invited a man named David to the apartment to buy the victim’s second television.  The defendant and Garcia said they then left the victim’s home, suggesting David had committed the murder.  The police were able to confirm David had an alibi, so they interviewed the defendant a second time.  During this second interview, the defendant said he had sold the victim’s TV to a man named Jason McCarthy.  McCarthy said when the defendant showed up at his house, his sweatshirt had red stains on it.  When McCarthy asked what happened, the defendant said, “I just murdered somebody….  No.  I was painting.”  The cops seized the television and subsequent tests revealed the presence of blood.  The cops arrested the defendant and Garcia and charged them with misleading the police.  Garcia then admitted he had lied about being with the defendant in the victim’s apartment.  What really happened, according to Garcia, was the defendant called him and asked for a ride from the victim’s home so he could deliver the television to McCarthy.  The police then swabbed the defendant’s hands and identified the presence of blood, and the police found the defendant’s bloody clothes and shoes.  The defendant was convicted of first-degree murder and sentenced to life in prison without the possibility of parole.  He appealed and the SJC affirmed.

The defendant’s primary appellate argument dealt with the admission of his statement to the police at trial.  The defendant had filed a motion to suppress, arguing that because he had not received Miranda warnings prior to speaking to the police, the Commonwealth should not have be able to share his statement with the jury.  Miranda warnings are required if two elements are satisfied: if a suspect is in custody; and if he is being interrogated by the police.  In this case, the Court concluded the defendant was not in custody at the time of his interview with the police, so he was not entitled to Miranda warnings.  In determining whether a suspect is in custody, courts consider four factors: the location of the interview; whether the person being interviewed has been told he is a suspect; the tone of the interview; and whether the person being interviewed could have ended the interview by leaving or asking the interrogator to leave.  In this case, the SJC noted the defendant showed up at the police station on his own, and the cops initially told him he was a witness, not a suspect.  The officers were calm and polite when dealing with the defendant and never told him during the first two interviews that he was not free to leave.  Based on all of these factors, the Court concluded the defendant was not in custody when he was speaking to the police and accordingly was not entitled to Miranda warnings.

As a result of the Court’s decision, the defendant’s first-degree murder conviction was upheld and he will spend the rest of his life in prison.