Dassey v. Dittmann - 877 F.3d 297 (7th Cir. 2017)

Rule:

The United States Supreme Court's many cases applying the voluntariness test have not distilled the doctrine into a comprehensive set of hard rules, though prohibitions on physical coercion are absolute. The Antiterrorism and Effective Death Penalty Act of 1996 does not require state and federal courts to wait for some nearly identical factual pattern before a legal rule must be applied because even a general standard may be applied in an unreasonable manner. Nevertheless, applying a general standard like voluntariness can demand a substantial element of judgment, and determining whether that judgment is reasonable requires considering the rule's specificity. The more general the rule, the more leeway courts have in reaching outcomes in case-by-case determinations. 

Facts:

Petitioner Brendan Dassey confessed on videotape to participating in the 2005 rape and murder of Teresa Halbach and the mutilation of her corpse. The Wisconsin state courts upheld Dassey's convictions for these crimes, finding that his confession was voluntary and could be used against him. The principal issue in this habeas corpus appeal is whether that finding was based on an unreasonable application of Supreme Court precedent or an unreasonable view of the facts. 

Issue:

Was the finding that Dassey’s confession was voluntary and could be used against him proper?

Answer:

Yes.

Conclusion:

The court held that the state appellate court's finding that Dassey’s confession was voluntary was not an unreasonable application of United States Supreme Court precedent as Dassey spoke with the interrogators freely, after receiving and understanding Miranda warnings, and with his mother's consent; the interrogation took place in a comfortable setting, without physical coercion and over a relatively brief time; petitioner provided many of the most damning details himself in response to open-ended questions and resisted the interrogators' strong suggestions on particular details; and no specific promises of leniency were made. The state appellate court drew on fairly detailed findings of fact, which were not clearly erroneous, and provided a sufficient explanation for why the trial court's decision was a reasonable application of the totality-of-the-circumstances test.