Saturday, November 2, 2013

Arizona v. Fulminante case brief

Arizona v. Fulminante case brief summary
499 U.S. 279 (1991)

The Supreme Court of Arizona held that the Fifth and Fourteenth Amendments barred defendant's confession which was admitted during his trial for murder, because it was coerced. The government appealed.

Defendant confessed to the murder of his stepdaughter to a fellow prisoner while he was incarcerated on other charges. The state supreme court ruled that the confession had been coerced and that the Fifth and Fourteenth Amendments barred its use against defendant.

  • The Court held that the confession was coerced and that the state failed to meet its burden of establishing, beyond a reasonable doubt, that the admission of the confession was harmless error. There was a credible threat of physical violence to defendant unless he confessed. 
  • Admission of a coerced confession did not automatically require reversal of a conviction but was subject to harmless error analysis because it involved a trial error that could be assessed in the context of other evidence. 
  • Admission of defendant's confession was not harmless error because it was unlikely that he would have been prosecuted at all absent the confession, the admission of the confession led to the admission of other evidence prejudicial to defendant, and the confession influenced the sentencing phase of the trial.


The judgment barring defendant's confession was affirmed.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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