Colorado v. Connelly

Colorado v. Francis Connelly
Supreme Court of the United States
Argued October 8, 1986 Decided December 10, 1986
Full case name	Colorado v. Connelly
Docket nos.	85-660
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
Chief Justice William Rehnquist Associate Justices William J. Brennan, Jr. · Byron White Thurgood Marshall · Harry Blackmun Lewis F. Powell, Jr. · John P. Stevens Sandra Day O'Connor · Antonin Scalia
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 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:

“

Coercive police activity is a necessary predicate to finding that a confession is not "voluntary" within the meaning of the Due Process Clause. Here, the taking of respondent's statements and their admission into evidence constituted no violation of that Clause. While a defendant's mental condition may be a "significant" factor in the "voluntariness" calculus, this does not justify a conclusion that his mental condition, by itself and apart from its relation to official coercion, should ever dispose of the inquiry into constitutional "voluntariness".[2]

”

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. *should be evaluated for bias*

See also

• List of United States Supreme Court cases, volume 479
• List of United States Supreme Court cases
• Lists of United States Supreme Court cases by volume
• List of United States Supreme Court cases by the Rehnquist Court
• Exclusionary rule

References

1. ^ "PsycLAW: Colorado v. Connelly". American Psychological Association. http://www.apa.org/psyclaw/colorado.html. Retrieved 2007-05-09. 
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

• Cheney, W. G. (1987). "Colorado v. Connelly: Is Free Will No Longer a Criteria for the Voluntariness of an Accused's Waiver and Confession Under Miranda?". Law & Psychology Review 11: 153. ISSN 00985961. 
• Oberlander, Lois B.; Goldstein, Naomi E. (2001). "A review and update on the practice of evaluating Miranda comprehension". Behavioral Sciences & the Law 19 (4): 453–471. doi:10.1002/bsl.453. PMID 11568955.