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Whether rooted directly in the Due Process Clause of the Fourteenth Amendment, or in the Compulsory Process or Confrontation Clauses of the Sixth Amendment, the U.S. Constitution guarantees criminal defendants a meaningful opportunity to present a complete defense. An essential component of procedural fairness is an opportunity to be heard. That opportunity would be an empty one if the state were permitted to exclude competent, reliable evidence bearing on the credibility of a confession when such evidence is central to the defendant's claim of innocence. In the absence of any valid state justification, exclusion of this kind of exculpatory evidence deprives a defendant of the basic right to have the prosecutor's case encounter and survive the crucible of meaningful adversarial testing.
A week after the liquor store clerk was killed, petitioner, Crane, then 16, was arrested for another crime. According to police, the petitioner began confessing to a host of crimes. Upon questioning, the petitioner initially denied involvement in the murder of the store clerk but then confessed to it. At trial, the defendant filed a motion to suppress the confession as having been involuntarily given. The trial court denied the motion, finding that the confession was voluntary. Because the prosecution had no physical or other evidence to link the defendant to the crime other than his confession, the defense was that his confession was given under circumstances that made its credibility suspect. The trial court, however, excluded all evidence regarding the circumstances under which the confession was given, concluding that such evidence related only to voluntariness, which had already been decided. Plaintiff sought review of an order from the Supreme Court of Kentucky, which affirmed his conviction for murder. Certiorari was granted.
Was the exclusion of testimony violated the petitioner’s rights under the Sixth and Fourteenth Amendments?
Yes. The Court reversed the defendant's conviction and remanded the case for further proceedings.
In overturning the conviction, the Court found that such evidence should have been admitted because its exclusion denied the defendant his Fourteenth and Sixth Amendment rights to present a complete defense. The evidence of the voluntariness and the credibility of the confession were not mutually exclusive. The court held that the exclusion of the testimony about the circumstances of his confession deprived the petitioner of his fundamental constitutional right whether under the Due Process Clause of the Fourteenth Amendment or under the Compulsory Process or Confrontation Clauses of the Sixth Amendment to a fair opportunity to present a defense. The court further held that the evidence about the manner in which a confession was secured, in addition to bearing on its voluntariness, often bears on its credibility, a matter that is exclusively for the jury to assess. Also, the physical and psychological environment that yielded a confession was not only relevant to the legal question of voluntariness but can also be of substantial relevance to the ultimate factual issue of the defendant's guilt or innocence, especially in a case such as this where there apparently was no physical evidence to link petitioner to the crime. Thus, the respondent's argument that any error was harmless since the excluded evidence came in through other witnesses should be directed in the first instance to the state court.