Tuesday, November 5, 2013

Colorado v. Connelly case brief

Colorado v. Connelly case brief summary
479 U.S. 157 (1986)

On certiorari to the Supreme Court of Colorado, the State challenged a ruling that suppressed defendant's confession to murder on grounds that defendant's mental illness at the time of confession compelled him to waive his Miranda rights and violated defendant's Fourteenth Amendment due process rights.

Defendant approached a police officer and, without any prompting, confessed to a murder. The officer immediately advised him of his Miranda rights and defendant said that he understood the rights. After another police officer arrived, defendant was again advised of his rights. Defendant was then held in custody and proceeded to confess to a child's murder. The next day, defendant stated for the first time that voices had told him to confess. On defendant's motion at a preliminary hearing, the trial court suppressed his initial statements and the custodial confession because they were involuntary.

  • On appeal, the Supreme Court of Colorado affirmed, holding that the admission of the evidence in a court of law would have violated the Due Process Clause of U.S. Constitutional Amendment XIV. 
  • On certiorari, the Court reversed, holding that absent police coercion, defendant's confession was not barred by either Miranda or the Due Process Clause.
The Court reversed the state court's decision. Defendant's confession was improperly suppressed because coercive police activity, absent in defendant's case, was a necessary predicate to the finding that defendant's confession was involuntary under the due process clause. Additionally, absent police coercion, the lower court erred in holding that defendant's waiver of his Miranda rights was involuntary.

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

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