Colorado v. Connelly
(Federal, Miranda Waiver and Mental Illness)
COLORADO v. CONNELLY
SUPREME COURT OF THE UNITED STATES
479 U.S. 157; 107 S. Ct. 515; 93 L. Ed. 2d 473; 1986 U.S.
October 8, 1986, Argued
December 10, 1986, Decided
CERTIORARI TO THE SUPREME COURT OF COLORADO.
DISPOSITION: 702 P. 2d 722, reversed and remanded.
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DECISION: Confession by suspect who claims that mental illness compelled him to waive Miranda rights and confess held admissible, absent police coercion, under due process clause and Miranda doctrine.
SUMMARY: A man approached a police officer in downtown Denver and, without any prompting, confessed to a murder. The officer immediately advised him of his Miranda rights, but the man said he understood these rights and still wanted to talk about the murder because his conscience was bothering him. After another police officer arrived, the man was again advised of his rights and was asked “what he had on his mind.” He answered that he had come all the way from Boston to confess to the murder of a young girl who had been killed in Denver. The man was taken to police headquarters, where he openly detailed his story to several officers and agreed to show them the scene of the killing. Two officers drove him there, and he pointed out the exact location of the murder. Having been held overnight, the man became visibly disoriented the next morning and stated for the first time that “voices” had told him to come to Denver and confess. The man was then sent to a state hospital and was evaluated by a psychiatrist. At a preliminary hearing before a Colorado trial court, the man moved to suppress all of his statements to the police. The psychiatrist who had evaluated the man testified that the man was experiencing “command hallucinations,” and that this psychotic condition had motivated his confession but had not impaired his ability to understand his Miranda rights. The court ruled that the initial statements and the custodial confession must be suppressed because they were involuntary, although the police had done nothing coercive in securing them. The Supreme Court of Colorado affirmed, holding that the admission of the evidence in a court of law would violate the due process clause of the Fourteenth Amendment, and that the man’s mental condition had precluded his ability to make a valid waiver of his Miranda rights (702 P2d 722).
On certiorari, the United States Supreme Court reversed and remanded. In an opinion by Rehnquist, Ch. J., joined by White, Powell, O’Connor, and Scalia, JJ., and in part (excepting holding (3) below) by Blackmun, J., it was held that (1) coercive police activity is a necessary predicate to the finding that a confession is not voluntary under the due process clause, (2) neither the taking of the man’s statements nor their admission into evidence constituted a violation of due process, (3) a state that bears the burden of proving waiver of Miranda rights meets that burden if it proves waiver by a preponderance of the evidence, and (4) absent proof of police coercion, the Colorado Supreme Court erred in holding that the waiver of Miranda rights was involuntary.
Blackmun, J., concurred in part and concurred in the judgment, expressing the view that the issue of the level of the state’s burden of proof in showing a waiver of Miranda rights was not necessary to the decision, since it had neither been raised nor briefed by the parties.
Stevens, J., concurred in the judgment in part and dissented in part, expressing the view that (1) although the precustodial statements were in fact involuntary, their use did not violate the Fifth Amendment because they were not the product of state compulsion, but (2) the postcustodial statements were inadmissible, since the man’s waiver of his Miranda rights was not the product of a free and deliberate choice, and thus his custodial interrogation was presumptively coercive.
Brennan, J., joined by Marshall, J., dissenting, expressed the view that (1) the absence of police wrongdoing does not, by itself, determine the voluntariness of a confession by a mentally ill person, (2) due process requires that a trial court find substantial indicia of reliability, based on extrinsic evidence, before admitting such a confession into evidence, (3) the government must prove voluntary waiver of Miranda rights beyond a reasonable doubt, (4) police coercion is not a requirement for a finding of involuntary waiver of Miranda rights, and (5) the Colorado Supreme Court was free on remand to reconsider such issues as whether the requirement of a knowing and intelligent waiver of Miranda rights was satisfied.