Colorado v. Francis Connelly | |
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Argued October 8, 1986 Decided December 10, 1986 | |
Full case name | Colorado v. Francis Barry Connelly |
Docket no. | 85-660 |
Citations | 479 U.S. 157 ( more ) 107 S. Ct. 515; 93 L. Ed. 2d 473 |
Case history | |
Prior | People v. Connelly, 702 P.2d 722 (Colo. 1985); cert. granted, 474 U.S. 1050(1986). |
Holding | |
As Connelly was not coerced by the police to divulge any information, his confession was voluntary, and there was no violation of the Due Process Clause. | |
Court membership | |
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Case opinions | |
Majority | Rehnquist, joined by White, Powell, O'Connor, Scalia; Blackmun (except Part III–A) |
Concurrence | Blackmun |
Concur/dissent | Stevens |
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. [1]
In Justice Brennan's dissent, he argued that this constituted an involuntary confession and that it violated a ''fundamental right to make a vital choice with a sane mind, involving a determination that could allow the state to deprive him of liberty or even life.'' [2]
Francis Connelly approached a Denver police officer and expressed interest in talking about a murder that he committed. After being read his rights, Connelly continued to want to confess to the murder, so a detective was called. The detective repeated Connelly's rights again, but Connelly remained willing to discuss the murder. Connelly then waived his right to counsel, and described the details of the murder.
Soon afterwards, the court determined that Connelly was not of sound enough mind to stand trial, and was given six months of therapy. After the six months was completed, Connelly stood trial. During the trial, the psychiatrist that evaluated Connelly testified that he believed that God told him to confess to the murder, or commit suicide. The lower court ruled that Connelly's waiver of his Miranda rights was made when he was incompetent due to his mental illness, so the confession of Connelly was not permitted in court. [3]
The case then went to the Colorado Supreme Court, where the local court's decision was upheld. The evidence of Connelly's confession was suppressed under the due process clause of the Fourteenth Amendment to the United States Constitution.
The Supreme Court heard the case, and decided that 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". [4]
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. [5] Before Connelly the test was whether the confession was voluntary considering the totality of the circumstances. [6] "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. [7] After Connelly the totality of circumstances test is not even triggered unless the defendant can show coercive police conduct. [8] 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.
In the United States, the Miranda warning is a type of notification customarily given by police to criminal suspects in police custody advising them of their right to silence and, in effect, protection from self-incrimination; that is, their right to refuse to answer questions or provide information to law enforcement or other officials. Named for the U.S. Supreme Court's 1966 decision Miranda v. Arizona, these rights are often referred to as Miranda rights. The purpose of such notification is to preserve the admissibility of their statements made during custodial interrogation in later criminal proceedings. The idea came from law professor Yale Kamisar, who subsequently was dubbed "the father of Miranda."
Miranda v. Arizona, 384 U.S. 436 (1966), was a landmark decision of the U.S. Supreme Court in which the Court ruled that law enforcement in the United States must warn a person of their constitutional rights before interrogating them, or else the person's statements cannot be used as evidence at their trial. Specifically, the Court held that under the Fifth Amendment to the U.S. Constitution, the government cannot use a person's statements made in response to an interrogation while in police custody as evidence at the person's criminal trial unless they can show that the person was informed of the right to consult with a lawyer before and during questioning, and of the right against self-incrimination before police questioning, and that the defendant not only understood these rights but also voluntarily waived them before answering questions.
Chambers v. Florida, 309 U.S. 227 (1940), was a landmark United States Supreme Court case that dealt with the extent to which police pressure resulting in a criminal defendant's confession violates the Due Process Clause.
Ernesto Arturo Miranda was an American laborer whose criminal conviction was set aside in the landmark U.S. Supreme Court case Miranda v. Arizona, which ruled that criminal suspects must be informed of their right against self-incrimination and their right to consult with an attorney before being questioned by police. This warning is known as a Miranda warning. Miranda had been convicted of kidnapping, rape, and armed robbery charges based on his confession under police interrogation.
In the United States, the exclusionary rule is a legal rule, based on constitutional law, that prevents evidence collected or analyzed in violation of the defendant's constitutional rights from being used in a court of law. This may be considered an example of a prophylactic rule formulated by the judiciary in order to protect a constitutional right. The exclusionary rule may also, in some circumstances at least, be considered to follow directly from the constitutional language, such as the Fifth Amendment's command that no person "shall be compelled in any criminal case to be a witness against himself" and that no person "shall be deprived of life, liberty or property without due process of law."
Dickerson v. United States, 530 U.S. 428 (2000), upheld the requirement that the Miranda warning be read to criminal suspects and struck down a federal statute that purported to overrule Miranda v. Arizona (1966).
In the law of criminal evidence, a confession is a statement by a suspect in crime which is adverse to that person. Some secondary authorities, such as Black's Law Dictionary, define a confession in more narrow terms, e.g. as "a statement admitting or acknowledging all facts necessary for conviction of a crime," which would be distinct from a mere admission of certain facts that, if true, would still not, by themselves, satisfy all the elements of the offense. The equivalent in civil cases is a statement against interest.
Brown v. Mississippi, 297 U.S. 278 (1936), was a United States Supreme Court case that ruled that a defendant's involuntary confession that is extracted by the use of force on the part of law enforcement cannot be entered as evidence and violates the Due Process Clause of the Fourteenth Amendment.
McNeil v. Wisconsin, 501 U.S. 171 (1991), held that the right to counsel secured by the Sixth Amendment and the right to counsel protected by Miranda v. Arizona are separate and distinct, such that invoking one does not implicitly invoke the other.
Massiah v. United States, 377 U.S. 201 (1964), was a case in which the Supreme Court of the United States held that the Sixth Amendment to the United States Constitution prohibits the government from eliciting statements from the defendant about themselves after the point that the Sixth Amendment right to counsel attaches.
The Fifth Amendment to the United States Constitution creates several constitutional rights, limiting governmental powers focusing on criminal procedures. It was ratified, along with nine other articles, in 1791 as part of the Bill of Rights.
Godinez v. Moran, 509 U.S. 389 (1993), was a landmark decision in which the U.S. Supreme Court ruled that if a defendant was competent to stand trial, they were automatically competent to plead guilty, and thereby waive the panoply of trial rights, including the right to counsel.
Fellers v. United States, 540 U.S. 519 (2004), is a United States Supreme Court case regarding the Sixth Amendment's right to counsel.
Michigan v. Jackson, 475 U.S. 625 (1986), was a case decided by the United States Supreme Court regarding the Sixth Amendment's right to counsel in a police interrogation. In a decision written by Justice Stevens, the Court held that once an accused individual has claimed a right to counsel at a plea hearing or other court proceeding, a waiver of that right during later police questioning would be invalid unless the accused individual initiated the communication.
Edwards v. Arizona, 451 U.S. 477 (1981), is a decision by the United States Supreme Court holding that once a defendant invokes his Fifth Amendment right to counsel, police must cease custodial interrogation. Re-interrogation is only permissible once defendant's counsel has been made available to him, or he himself initiates further communication, exchanges, or conversations with the police. Statements obtained in violation of this rule are a violation of a defendant's Fifth Amendment rights.
Berghuis v. Thompkins, 560 U.S. 370 (2010), is a landmark decision by the Supreme Court of the United States in which the Court considered the position of a suspect who understands their right to remain silent under Miranda v. Arizona and is aware that they have the right to remain silent, but does not explicitly invoke or waive the right.
Brewer v. Williams, 430 U.S. 387 (1977), is a decision by the United States Supreme Court that clarifies what constitutes "waiver" of the right to counsel for the purposes of the Sixth Amendment. Under Miranda v. Arizona, evidence obtained by police during interrogation of a suspect before he has been read his Miranda rights is inadmissible. Here, however, the defendant had been indicted in court and had asserted his desire to have counsel, thus his Sixth Amendment right to counsel had attached. At issue was whether a voluntary admission of incriminating facts in response to police statements made while the defendant was in custody and outside the presence of his lawyer constituted a waiver of this right to counsel.
Colorado v. Spring, 479 U.S. 564 (1987), was a United States Supreme Court case in which the Court held that a suspect's awareness of the crimes about which he may be questioned is not relevant to his waiver of his Fifth Amendment rights.
Illinois v. Perkins, 496 U.S. 292 (1990), was a decision by the United States Supreme Court that held that undercover police agents did not need to give Miranda warnings when talking to suspects in jail. Miranda warnings, named after the 1966 Supreme Court case Miranda v. Arizona, are generally required when police interrogate suspects in custody in order to protect the right not to self-incriminate and the right to counsel under the Fifth and Sixth Amendments. However, the Court ruled that potential coercion must be evaluated from the suspect's point of view, and if they are unaware that they are speaking to police, they are not under the coercive pressure of a normal interrogation.
Crooker v. California, 357 U.S. 433 (1958), was a decision by the Supreme Court of the United States that limited criminal suspects' constitutional right to counsel before trial, refusing to overturn a subsequent conviction without a showing that the refusal of counsel had a coercive or prejudicial effect. This holding was later overturned by Escobedo v. Illinois and Miranda v. Arizona.