1986 United States Supreme Court case
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]
Prior history
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.
Case
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]
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.[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.
