Why is the case important?
An individual with a history of mental illness approached a police officer and confessed to a murder.
Facts of the case
In 1983, Francis Connelly approached a police officer and, without any prompting, confessed to murder. The police officer immediately informed Connelly that he had the right to remain silent, but Connelly indicated that he still wished to discuss the murder. It was later discovered that Connelly was suffering from chronic schizophrenia at the time of the confession. A Colorado trial court suppressed the statements on the ground that they were made involuntarily.
Whether the United States Constitution (Constitution) requires a court to suppress a confession when the mental state of the defendant, at the time he made the confession, interfered with his ‘rational intellect’ and his ‘free will?’
The admissibility of this kind of statement is governed by state rules of evidence, rather than by the Supreme Court’s previous decisions regarding coerced confessions and Miranda waivers.
The court observed, the difficulty with the approach of the Supreme Court of Colorado is that it fails to recognize the essential link between coercive activity of the State, on the one hand, and a resulting confession by a defendant, on the other. Further, the flaw in respondent’s constitutional argument is that it would expand the Supreme Court’s previous line of ‘voluntariness’ cases into a far ranging requirement that courts must divine a defendant’s motivation for speaking or acting as he did even though there be no claim that governmental conduct coerced his decision.
Moreover, suppressing respondent’s statements would serve absolutely no purpose in enforcing constitutional guarantees. The purpose of excluding evidence seized in violation of the Constitution is to substantially deter future violations of the Constitution. Only if we were to establish a brand new constitutional right – the right of a criminal defendant to confess to his crime only when totally rational and properly motivated – could respondent’s present claim be sustained.
The majority further concluded that the state court was incorrect in finding that that the State must bear its burden of proving waiver of these Miranda rights by ‘clear and convincing evidence.’ Whenever the State bears the burden of proof in a motion to suppress a statement that the defendant claims was obtained in violation of our Miranda doctrine, the State need prove waiver only by a preponderance of the evidence.
The Supreme Court of Colorado was also wrong in analysis of the question whether respondent had waived his Miranda rights in this case. The Supreme Court of Colorado was incorrect in importing into this area of constitutional law notions of ‘free will’ that have no place there. The voluntariness of a waiver of this privilege has always depended on the absence of police overreaching, not on free choice in any broader sense of the word. Respondent’s perception of coercion flowing from the ‘voice of God,’ however important or significant such a perception may be in other disciplines, is a matter to which the United States Constitution does not speak.
Dissent: Justice William Brennan (J. Brennan) and Justice Thurgood Marshall (J. Marshall) filed a dissenting opinion arguing the use of a mentally ill person’s involuntary confession is antithetical to the notion of fundamental fairness embodied in the Due Process Clause.
On a writ of certiorari, the Supreme Court of the United States held that coercive police activity is a necessary predicate to the finding that a confession is not voluntary under the Due Process Clause, U.S. Const. Amend. XIV . In the case at bar, neither the taking of Connelly’s statements nor their admission into evidence constituted a violation of due process. According to the Court, absent proof of police coercion, the Colorado Supreme Court erred in holding that the waiver of Miranda rights was involuntary. The Court reversed the judgment.
- Case Brief: 1986
- Petitioner: Colorado
- Respondent: Francis Connelly
- Decided by: Rehnquist Court
Citation: 479 US 157 (1986)
Argued: Oct 8, 1986
Decided: Dec 10, 1986