## Facts

- Michael Caputo was convicted in Massachusetts of two counts of first-degree murder for the 1989 stabbing deaths of his estranged wife and mother-in-law.
- Police responding to the scene found evidence suggesting forced entry and a protective order directing Caputo to stay away from the apartment, listing his address.
- Plymouth police went to Caputo’s home, entered with his permission, and informed him they were investigating a double homicide.
- An officer administered Miranda warnings from a card; Caputo initially said he did not understand, then affirmed understanding after each right was restated individually.
- Caputo stated he thought it best to say nothing further; officers immediately stopped questioning.
- Officers remained in the house and were not asked to leave.
- After overhearing a telephone conversation related to the investigation, Caputo initiated conversation and made inculpatory statements without express questioning by police.
- Caputo moved to suppress the statements as taken in violation of the Fifth Amendment and Miranda; the state courts denied suppression and affirmed the convictions.
- Caputo sought federal habeas relief under 28 U.S.C. § 2254; the district court denied the petition, and Caputo appealed.

## Issues

1. Whether admitting Caputo’s post-invocation statements violated the Fifth Amendment and Miranda because police conduct after he invoked silence constituted “interrogation” or its functional equivalent.
2. Whether, under AEDPA, the state court’s rejection of the Miranda claim was contrary to, or an unreasonable application of, clearly established Supreme Court precedent.
3. Whether any later statements were inadmissible as derivative evidence if an earlier Miranda violation occurred.

## Decision

- The First Circuit affirmed the denial of habeas relief.
- The court held the state court’s decision was neither contrary to, nor an unreasonable application of, clearly established federal law.
- The court accepted as reasonable the state court’s conclusion that police honored Caputo’s invocation, and that his later statements were spontaneous rather than the product of interrogation.
- The court rejected the derivative-evidence argument because it found no predicate constitutional violation.

## Legal Principles

- Under AEDPA, federal habeas relief is available only if the state court decision is contrary to, or an unreasonable application of, clearly established Supreme Court law, or rests on an unreasonable factual determination; mere error is insufficient.
- For Miranda purposes, “interrogation” includes express questioning and its functional equivalent: police words or actions they should know are reasonably likely to elicit an incriminating response (Rhode Island v. Innis).
- When a suspect invokes the right to remain silent, police must cease questioning; voluntary, unprompted statements initiated by the suspect are admissible absent interrogation-like conduct.
- Ordinary police conduct in a suspect’s presence, without a reasonable likelihood of eliciting an incriminating response, is not interrogation.
- A “fruit of the poisonous tree” theory does not apply without an underlying constitutional violation.

## Conclusion

The First Circuit held that, given AEDPA deference and the Innis definition of interrogation, the state court reasonably concluded Caputo’s post-invocation statements were voluntary and not elicited through interrogation; therefore, their admission did not warrant federal habeas relief.


Caputo v. Nelson, 455 F.3d 45 (1st Cir. 2006)