Crane v. Kentucky

LOCATION: Nassau County School Board

DOCKET NO.: 85-5238
DECIDED BY: Burger Court (1981-1986)
LOWER COURT: Kentucky Supreme Court

CITATION: 476 US 683 (1986)
ARGUED: Apr 23, 1986
DECIDED: Jun 09, 1986

Frank W. Heft, Jr. - on behalf of the petitioner
John S. Gillig - on behalf of the respondent

Facts of the case

The case study illustrates the situation in which a fundamental constitutional right of the individual was not protected. Before the court hearing, the petitioner moved in order to suppress the confession. After the trial, the judges decided that the confession was voluntary; hence, they rejected the complaint.

The convicted man tried to prove his point at the trial by trying to present the testimony, which gave details of the interrogation. He wanted to show that the manner of interrogation and the circumstances were inappropriate. With this testimony, he was hoping to explain that the confession under such conditions should not be regarded trustworthy.

All that the judges could see in the testimony was regarded as the voluntariness issue. The document was called inadmissible, and thus the verdict did not change. The Supreme Court of Kentucky concluded that the appellant was guilty and that there was no violation of the 6th and 14th Amendments in regard to his case.

This case brief is an example of the absence of an opportunity to perform defense. The evidence presented by the petitioner should have been taken into account. The psychological and physical environment has beaten the confession out of the person in this particular situation. Given the earlier facts of the case, it is apparent that the guilt was not 100% evident. Therefore, it was wrong to dismiss the testimony of the petitioner. In addition to that, the argument of the responded that this mistake was insignificant should have been sent to the state court.


Media for Crane v. Kentucky

Audio Transcription for Oral Argument - April 23, 1986 in Crane v. Kentucky

But didn't the trial court say you could produce evidence as to inaccuracies?

John S. Gillig:

We would have to rest, I believe, on this case on the fact that the suppression hearing is there to make an initial determination of voluntariness.

Frank W. Heft, Jr.:

Yes, and indeed defense counsel did introduce that evidence.

You have used the word, in fact, we all use the word voluntariness.

Frank W. Heft, Jr.:

We introduced evidence about the misstatement of the gun and the fact that an alarm... the petitioner said an alarm sounded, and there was no alarm, the fact that the petitioner said he stole money--

Do you think voluntariness is kind of an either/or proposition, or do you think there are possibly degrees of voluntariness, and some confessions are a good deal more volunteer than others?

But they were simply mistakes in the confession.

John S. Gillig:

Well, certainly there are degrees of voluntariness.

Frank W. Heft, Jr.:

--But there is a reason for those mistakes, Your Honor, and the jury was precluded from hearing any evidence as to why the petitioners made those statements, and the facts surrounding the procurement of the confession are germane to a determination of why the petitioner made those statements.

And here the finding in the suppression hearing is that it crosses at least a minimum threshold sufficient to make it admissible, but could it not be possible that it would still be relevant... the whole area of how voluntary it was would nevertheless be relevant on the question of credibility in almost every case?

Frank W. Heft, Jr.:

The petitioner here was interrogated for a period of time, approximately an hour and 40 minutes, and indeed the jury was not informed of the fact that the petitioner was questioned and talked about this particular liquor store robbery for some nearly 45 minutes before he gave the written waiver of his constitutional rights, and before the statement was actually taped.

John S. Gillig:

Well, I believe--

Frank W. Heft, Jr.:

Surely those circumstances are germane to the issue of credibility because what happened in that interrogation room does have a bearing on why the petitioner--

He walks in himself without any pre-warning and says, I want to confess to a crime I committed last Thursday at 8:00 o'clock.

I thought the only two facts that you wanted to get in that you couldn't get in was the size of the room and the number of officers in it.

You get one picture there of somebody who sits in a small room with four police officers for an hour and a half and ends up by confession.

Frank W. Heft, Jr.:

--That's true.

Maybe that is not quite as voluntary as the first example--

Frank W. Heft, Jr.:

We wanted to get those facts in.

John S. Gillig:

--Yes, Your Honor.

Those are the only two facts that you wanted to get before the jury that you didn't get before the jury.

--even though it would be admissible.

Frank W. Heft, Jr.:

Well, when the confession was--

John S. Gillig:

And so I think that in each individual case then it would depend on what the defendant was arguing when he got to trial and said I want to argue credibility now, so that you wouldn't just say just because the defendant lost the voluntariness hearing, therefore all circumstances of the confession are always admissible, which is exactly what petitioner wants.

Is that true or not?

John S. Gillig:

Petitioner wants that to say there is no distinction, therefore all the facts are admissible, and so we would disagree with that.

Frank W. Heft, Jr.:

--Yes, that... and the length of time of the interrogation.

John S. Gillig:

It would be an evaluative thing by the trial court in the first instance--

Yes, well, but you say even if those are the only facts, they were still very relevant to reliability.

What would be wrong with a rule that said this opens the gates and let everything in to tell the full story of the circumstances surrounding the confession and the extent to which it was voluntary, how tired he was and all that?