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Colorado v. Connelly

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Title: Colorado v. Connelly  
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Colorado v. Connelly

Colorado v. Francis Connelly
Argued October 8, 1986
Decided December 10, 1986
Full case name Colorado v. Connelly
Docket nos. 85-660
Citations 479 U.S. 157 (more)
Holding
Because Connelly was not coerced by the Government to divulge any information, his statement should be allowed in Court due to the lack of violation of the Due Process Clause.
Court membership
Case opinions
Majority Rehnquist, joined by White, Blackmun, Powell, Stevens, O'Connor, Scalia
Dissent Brennan, joined by Marshall
Laws applied
U.S. Const. Amend. XIV

Colorado v. Connelly, 479 U.S. 157 (1986), was a U.S. Supreme Court case that was initiated by Francis Connelly, who insisted that his schizophrenic episode rendered him incompetent, nullifying his waiver of his Miranda rights.

Prior history

Francis Connelly approached a Denver police officer and expressed interest in talking about a murder that he committed. After being read his rights, Mr. Connelly continued to want to confess to the murder, so a detective was called. The detective repeated Mr. Connelly's rights again, but Mr. Connelly remained willing to discuss the murder. Mr. Connelly then waived his right to counsel, and described the details of the murder.

Soon afterwards, the court determined that Mr. Connelly was not of sound enough mind to stand trial, and was given six months of therapy. After the six months was completed, Mr. Connelly stood trial. During the trial, the psychiatrist that evaluated Mr. Connelly testified that he believed that God told him to confess to the murder, or commit suicide. The lower court ruled that Mr. Connelly's waiver of his Miranda rights was made when he was incompetent due to his mental illness, so the confession of Mr. Connelly was not permitted in court. [1]

The case then went to the Colorado Supreme Court, where the local court's decision was upheld. The evidence of Mr. Connelly's confession was suppressed under the due process clause of the Fourteenth Amendment to the United States Constitution.

Case

The Supreme Court heard the case, and decided that Mr. Connelly's confession should not have been suppressed, due to a specific sentence in Miranda v. Arizona that stated that confessions may only be thrown out if the accused is coercively interrogated by the government. The Supreme Court reversed the Colorado Supreme Court's decision to suppress the evidence, stating that there was no violation of the due process clause. In the words of the Supreme Court:

Consequences

Connelly significantly changed the voluntariness standard - the test used to determine the admissibility of confessions under the due process clauses of the Fifth and Fourteenth Amendments.[3] Before Connelly the test was whether the confession was voluntary considering the totality of the circumstances.[4] "Voluntary" carried its everyday meaning: the confession had to be a product of the exercise of the defendant's free will rather than police coercion.[5] After Connelly the totality of circumstances test is not even triggered unless the defendant can show coercive police conduct.[6] Questions of free will and rational decision making are irrelevant to a due process claim unless police misconduct existed and a causal connection can be shown between the misconduct and the confession.

See also

References

  1. ^ "PsycLAW: Colorado v. Connelly".  
  2. ^ FindLaw for Legal Professionals. Retrieved on 2007-05-09.
  3. ^ Connelly also affects the determination of whether a waiver of Fifth or Sixth Amendment rights was voluntary. Also, a Massiah or Miranda defective statement can be used to impeach the defendant if the statement was voluntary. Alternatively, Connelly could be read as merely emphasizing the requirement of state action as a predicate to a constitutional challenge and rebuffing the lower court's determination that admitting the confession was sufficient state action.
  4. ^ See Mincey v. Arizona, 437 U.S. 385 (1978); Greenwald v. Wisconsin, 390 U. S. 519, 390 U. S. 521 (1968) ("Considering the totality of these circumstances, we do not think it credible that petitioner's statements were the product of his free and rational choice"); Reck v. Pate, 367 U. S. 433, 367 U. S. 440 (1961) ("If [a defendant's will was overborne], the confession cannot be deemed `the product of a rational intellect and a free will"')
  5. ^ See e.g., Culombe v. Connecticut, 367 U. S. 568, 367 U. S. 583 (1961) ("[A]n extrajudicial confession, if it was to be offered in evidence against a man, must be the product of his own free choice")
  6. ^ Bloom & Brodin, Criminal Procedure (Aspen 1996) at 247.

Further reading

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