Law School Case Brief
Colorado v. Connelly - 479 U.S. 157, 107 S. Ct. 515 (1986)
Coercive 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.
Respondent Francis Connelly approached Officer Patrick Anderson of the Denver Police Department working in an off-duty capacity in downtown Denver and, without any prompting, confessed to a murder. The officer immediately advised him of his Miranda rights, but Connelly said he understood these rights and still wanted to talk about the murder because his conscience was bothering him. After another police officer arrived, Connelly 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. Connelly 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, Connelly became visibly disoriented the next morning and stated for the first time that "voices" had told him to come to Denver and confess. Connelly was then sent to a state hospital and was evaluated by a psychiatrist. At a preliminary hearing before a Colorado trial court, Connelly moved to suppress all of his statements to the police. The psychiatrist who had evaluated him testified that Connelly 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 Connelly’s mental condition had precluded his ability to make a valid waiver of his Miranda rights.
Was defendant Connelly’s confession to the Denver police officers made involuntarily, thereby, also making an invalid waiver of his Miranda rights?
On a writ of certiorari, the Supreme Court of the United States held that coercive police activity is a necessary predicate to the finding that a confession is not voluntary under the Due Process Clause, U.S. Const. Amend. XIV. In the case at bar, neither the taking of Connelly’s statements nor their admission into evidence constituted a violation of due process. According to the Court, absent proof of police coercion, the Colorado Supreme Court erred in holding that the waiver of Miranda rights was involuntary. The Court reversed the judgment.
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