Colorado v. Connelly

Brief Fact Summary. An individual with a history of mental illness approached a police officer and confessed to a murder.

Synopsis of Rule of Law. “[C]oercive police activity is a necessary predicate to the finding that a confession is not ‘voluntary’ within the meaning of the Due Process Clause of the Fourteenth Amendment. [A]lso [ ] that the taking of respondent’s statements, and their admission into evidence, constitute no violation of that Clause.”

Facts. The Respondent, Francis Connelly (the “Respondent”) approached an off duty police officer and without any provocation told the officer he murdered somebody and wanted to talk about it. The officer advised the Respondent of his Miranda rights. The Respondent said he understood, but wanted to still talk about the murder. The Respondent informed the officer he had been in mental hospitals in the past, but that he was not currently under the influence of any substances. The officer felt that the Respondent understood what he was doing. A detective arrived shortly thereafter and asked the Respondent “what he had on his mind”. The Respondent confessed to the officers that he killed a young girl in Colorado in the past.
The Respondent was then taken to the police station and the police learned an unidentified female had been found at about the time the Respondent said he killed the little girl. The Respondent then took the officers to the scene of the crime. At this time, the Respondent did not exhibit any signs of mental illness.
The Respondent was held overnight and the next day during an interview with a public defender began exhibiting signs of disorientation. Including, the hearing of voices. He was then sent to a mental hospital, but eventually was deemed competent to proceed at trial.
During a preliminary hearing, the Respondent moved to suppress all his statements. A state doctor testified that the Respondent was suffering from chronic schizophrenia and was in a psychotic state the day before he confessed. Specifically, that he was following the voice of god from the time he came to Colorado from Boston to the time he confessed.
Based on the doctors testimony, “the Colorado trial court decided that respondent’s statements must be suppressed because they were ‘involuntary.’ [T]he court ruled that a confession is admissible only if it is a product of the defendant’s rational intellect and ‘free will.’ Although the court found that the police had done nothing wrong or coercive in securing respondent’s confession, Connelly’s illness destroyed his volition and compelled him to confess. The trial court also found that Connelly’s mental state vitiated his attempted waiver of the right to counsel and the privilege against compulsory self-incrimination. Accordingly, respondent’s initial statements and his custodial confession were suppressed.”
The Colorado Supreme Court affimed and found the “proper test for admissibility is whether the statements are ‘the product of a rational intellect and a free will.’ ”

Issue. Whether the United States Constitution (“Constitution”) “requires a court to suppress a confession when the mental state of the defendant, at the time he made the confession, interfered with his ‘rational intellect’ and his ‘free will[?]’ ”

Held. “[T]he admissibility of this kind of statement is governed by state rules of evidence, rather than by [the Supreme Court’s] previous decisions regarding coerced confessions and Miranda waivers.”
The court observed, “[t]he difficulty with the approach of the Supreme Court of Colorado is that it fails to recognize the essential link between coercive activity of the State, on the one hand, and a resulting confession by a defendant, on the other.” Further, “[t]he flaw in respondent’s constitutional argument is that it would expand [the Supreme Court’s] previous line of ‘voluntariness’ cases into a far ranging requirement that courts must divine a defendant’s motivation for speaking or acting as he did even though there be no claim that governmental conduct coerced his decision.”
“Moreover, suppressing respondent’s statements would serve absolutely no purpose in enforcing constitutional guarantees. The purpose of excluding evidence seized in violation of the Constitution is to substantially deter future violations of the Constitution. Only if we were to establish a brand new constitutional right – the right of a criminal defendant to confess to his crime only when totally rational and properly motivated – could respondent’s present claim be sustained.”
The majority further concluded that the state court was incorrect in finding that that “the State must bear its burden of proving waiver of these Miranda rights by ‘clear and convincing evidence.’ ” “Whenever the State bears the burden of proof in a motion to suppress a statement that the defendant claims was obtained in violation of our Miranda doctrine, the State need prove waiver only by a preponderance of the evidence.”
The Supreme Court of Colorado was also wrong in “analysis of the question whether respondent had waived his Miranda rights in this case.” The Supreme Court of Colorado was incorrect in “importing into this area of constitutional law notions of ‘free will’ that have no place there.” “The voluntariness of a waiver of this privilege has always depended on the absence of police overreaching, not on “free choice” in any broader sense of the word.” “Respondent’s perception of coercion flowing from the ‘voice of God,’ however important or significant such a perception may be in other disciplines, is a matter to which the United States Constitution does not speak.”
Dissent: Justice William Brennan (“J. Brennan”) and Justice Thurgood Marshall (“J. Marshall”) filed a dissenting opinion arguing “the use of a mentally ill person’s involuntary confession is antithetical to the notion of fundamental fairness embodied in the Due Process Clause.”

Discussion. In this case, the court refused to expand upon the protections a defendant enjoys under the Constitution because the suppression of this type of confession would not deter law enforcements’ misdeeds.