Commonwealth v. Camuti: Massachusetts SJC Upholds Murder Conviction in Cyanide Killing Linked to Whitey Bulger Trial
On April 9, 2025, the Massachusetts Supreme Judicial Court (SJC) issued its decision in Commonwealth v. William J. Camuti, SJC-13532, affirming Camuti’s convictions for first-degree murder, improper disposal of a body, and misleading a police officer. The court rejected his arguments that key evidence and post-Miranda statements should have been suppressed, ruling that law enforcement had probable cause for the searches and that Camuti’s confessions were voluntary.
This tragic, unusual, and high-profile case was deeply intertwined with the notorious Whitey Bulger saga. The victim, Stephen Rakes, was a potential witness in Bulger’s 2013 federal trial. Camuti, an old friend of Rakes, lured him to a meeting in Waltham, laced his coffee with cyanide, and disposed of the body in a wooded area of Lincoln.
The court’s decision in Camuti provides a detailed window into modern Massachusetts law on motions to suppress, custodial statements, mental competence after a suicide attempt, and the bounds of Miranda protections. For Massachusetts defense attorneys and criminal law practitioners, the opinion is both sobering and instructive.
Case Background: Cyanide, Deception, and the Murder of Stephen Rakes
The Discovery
On July 17, 2013, a passerby found Stephen Rakes’ body lying in a wooded area near Mill Street in Lincoln. The 59-year-old was dressed in the same clothes he had been seen wearing the day before. No obvious signs of trauma were present, but the medical examiner later determined the cause of death to be acute cyanide toxicity.
Police eventually identified Rakes via fingerprint records and immediately began piecing together his final hours.
The Suspect: William Camuti
William J. Camuti was no stranger to Rakes. The two had been close friends for over 30 years and had worked together on several real estate ventures. Camuti also owed Rakes $100,000—a significant sum, particularly given that Camuti was reportedly in financial ruin at the time, facing eviction and steep debts.
Investigators quickly discovered that the last phone calls made from Rakes’ phone were to Camuti. As surveillance, search warrants, and digital evidence would later confirm, Camuti orchestrated a meeting with Rakes at a Waltham fast-food restaurant on July 16, 2013. There, he offered the victim iced coffee—laced with potassium cyanide.
Rakes died over the course of several hours in Camuti’s car. Rather than seek help, Camuti drove around with the body for most of the day, eventually leaving it in the woods after dark.
Legal Issues on Appeal: Search Warrants and Miranda Waivers
Camuti challenged his conviction on two primary legal grounds:
That the search warrants used to obtain evidence from his residence, phone, car, and digital records were not supported by probable cause; and
That his confessions, obtained during police interviews from his hospital bed after a suicide attempt, were involuntary and inadmissible due to an invalid Miranda waiver.
The SJC rejected both arguments, affirming the trial court’s rulings on each motion to suppress.
Probable Cause and the Search Warrants
The defense argued that the warrants issued on July 19, 2013, lacked probable cause because they relied on inconsistencies and circumstantial facts, not direct evidence of a crime. But the SJC disagreed, holding that under both the Fourth Amendment and Article 14 of the Massachusetts Declaration of Rights, the detailed affidavit submitted by police supported reasonable belief that:
Camuti attempted larceny by false pretenses (by falsely claiming a check was in the mail to Rakes regarding the sale of a Bulger-related judgment); and
Camuti was likely involved in the improper disposal of Rakes’ body.
Among the key facts cited in the warrant affidavit:
Camuti gave inconsistent and demonstrably false statements to police about the meeting with Rakes;
A recorded call by Rakes on the morning of July 16 contradicted Camuti’s account;
Camuti claimed to show Rakes an 11-acre real estate parcel in Wilmington, which did not exist;
Rakes’ body was dumped in the woods, without ID, and with his jewelry missing;
Camuti was the last known person to have seen Rakes alive.
The court applied a commonsense, totality-of-the-circumstances approach, citing Commonwealth v. Dunn, 494 Mass. 42 (2024), and Commonwealth v. Long, 482 Mass. 804 (2019). It concluded that these facts created a strong nexus between the suspected crimes, the items sought, and the places to be searched.
Takeaway for defense attorneys: Even without direct eyewitnesses or forensic evidence at the scene, a detailed pattern of deception, digital evidence, and financial motive can be sufficient to support probable cause.
Voluntariness of Confession After a Suicide Attempt
Camuti also challenged the admission of his statements to police on July 21 and July 23, 2013. These interviews took place while Camuti was hospitalized after a suicide attempt, during which he had severely lacerated his wrists with a razor.
The court acknowledged the serious nature of Camuti’s physical and emotional state—but nonetheless upheld the trial judge’s finding that Camuti:
Was alert, coherent, and rational during the interviews;
Stated he understood his Miranda rights and waived them voluntarily;
Made his statements without any coercion, inducement, or pressure;
Refused to allow the interviews to be recorded;
Ended one interview himself when he became tired.
Both the defense and prosecution presented expert psychiatric testimony. While the defense claimed Camuti’s mental state rendered him incapable of making knowing, intelligent decisions, the Commonwealth’s expert disagreed, and the judge found that Camuti’s statements were reliable and voluntary under the standard set by Commonwealth v. Rivera, 482 Mass. 259 (2019).
The court emphasized that even when a defendant is emotionally distressed or recovering from physical trauma, a statement may still be voluntary if made with rational understanding and free will.
Key quote:
"The fact that a defendant may have been in a disturbed emotional state, or even suicidal, does not automatically make statements involuntary." — Rivera, 482 Mass. at 266
Evidence Presented at Trial
Camuti’s conviction rested not only on his confessions but also on corroborating physical and digital evidence, including:
GPS data from his vehicle showing his movements on July 16;
A receipt showing he bought two iced coffees at 1:07 p.m.—one of which was poisoned;
Surveillance videos and cell phone location data placing him at relevant locations;
A receipt for latex gloves purchased earlier that day;
A post-arrest vehicle cleaning, suggesting consciousness of guilt;
A forensic search of Camuti’s computer showing over 100 searches for “cyanide,” including detailed queries like “Can I mix potassium cyanide in coffee?”
The Commonwealth’s theory was clear: Camuti, deep in debt and desperate, lured Rakes to a meeting under false pretenses, poisoned his coffee with cyanide, and then tried to cover his tracks.
The jury convicted him of murder in the first degree by deliberate premeditation, as well as misleading police and unlawful disposal of a body. He was sentenced to life without parole and concurrent terms of 5–7 years for the misleading charges.
SJC’s Review Under G.L. c. 278, § 33E
Because this was a first-degree murder conviction, the SJC conducted a full review of the record under G.L. c. 278, § 33E, which permits the court to grant a new trial or reduce a murder conviction sua sponte if justice so requires.
Camuti’s appeal included a request under § 33E to reduce the murder conviction to a lesser degree or order a new trial. But the court saw no miscarriage of justice, no improper jury instruction, and no compelling reason to disturb the jury’s verdict.
The SJC affirmed the convictions in full.
Defense Strategy Lessons from Commonwealth v. Camuti
1. Don’t Overlook the Psychological State Defense—But Don’t Overestimate It
Camuti’s team mounted a serious challenge to the voluntariness of his statements, backed by expert testimony. But without demonstrable coercion or evidence that he was cognitively impaired at the time of the confession, the court deferred to the trial judge’s evaluation of his demeanor and understanding.
2. Expect Search Warrants to Be Upheld When Based on Contradictions
Camuti’s falsehoods to police significantly contributed to the finding of probable cause. Defense attorneys should prepare to rebut narrative inconsistencies head-on, rather than hope that vague or circumstantial facts alone will defeat a warrant.
3. Don’t Rely on Lack of Forensic Evidence Alone
Though there was no DNA or forensic proof directly tying Camuti to the victim’s body, the digital trail (GPS, internet history, recorded calls) proved decisive. In the digital age, circumstantial evidence often closes the loop.
Final Thoughts: Camuti as a Modern Massachusetts Murder Case
Commonwealth v. Camuti is a chilling case of calculated murder wrapped in financial desperation and deception. It also illustrates how Massachusetts courts scrutinize motions to suppress, assess mental competency after trauma, and weigh constitutional rights in the real world.
For attorneys handling murder appeals or complex suppression hearings, this decision underscores that credibility, consistency, and context are key—and that Massachusetts courts continue to give weight to solid police work, logical inference, and well-documented investigative records.