Law School Case Brief
Miller v. Fenton - 796 F.2d 598 (3d Cir. 1986)
To determine the voluntariness of a confession, a court must consider the effect that the totality of the circumstances has upon the will of the defendant. The question in each case is whether the defendant's will is overborne when he confesses. Factors to be considered include: the youth of the accused; his lack of education or his low intelligence; the lack of any advice to the accused of his constitutional rights; the length of detention; the repeated and prolonged nature of questioning; and the use of physical punishment. Using the flexible totality of the circumstances approach requires the reviewing court to consider the specific tactics utilized by the police in eliciting the admissions, the details of the interrogation, and the characteristics of the accused. Although at the trial level the burden is on the government to establish, by a preponderance of the evidence, that a challenged confession is voluntary, on collateral review, the habeas corpus petitioner must prove involuntariness by a preponderance of the evidence.
Brothers of Deborah Margolin, who was brutally murdered, described the stranger who approached Margolin before she was killed. The description fit defendant Frank Miller. Thereafter, the state police questioned Miller at his place of his employment. After a brief discussion, he agreed to accompany the officers to the police barracks for further questioning. He was then taken into an interrogation room by Detective Boyce and read his Miranda rights. Defendant signed a Miranda card, thus, waiving his Miranda rights, and Boyce’s interrogation ensured. One hour into the interrogation, Defendant confessed to the murder of Margolin, then passed out. Defendant was indicted for first-degree murder. Before his trial, Defendant moved to suppress the confession as involuntary, but the state trial court denied the motion. After a trial at which the confession was received as evidence, Defendant was convicted. On appeal of the conviction, a three-judge panel of the Appellate Division of the New Jersey Superior Court unanimously reversed, finding that Detective Boyce’s technique in eliciting the confession had denied Defendant due process of law. Characterizing Boyce's method of interrogation as "psychological pressure,” the panel held that as a result of that pressure, Miller's confession had not been voluntary. However, the New Jersey Supreme Court reversed the Appellate Division and reinstated the conviction. Looking at the totality of the circumstances, the state supreme court held that Boyce's interrogation tactics had not overborne defendant’s will, and that the confession had indeed been voluntary and thus properly admissible into evidence. The United States Supreme Court granted defendant Miller's petition for certiorari review.
Was Boyce’s method of interrogation a psychological pressure upon Miller, which resulted in defendant's confession involuntary?
After considering the totality of the circumstances that surrounded the interrogation, the Court affirmed the conviction. The Court held that Miller's background was not susceptible to psychological manipulation because he was a mature adult of average intelligence that had previous experience with the criminal justice system. The Court held that the interrogating officer's friendly demeanor was not improper because a good guy approach was a permissible interrogation tactic. The Court held that the interrogating officer's promises to Miller were not improper because Miller had been warned that anything he said could be used against him and was not told that he would not be prosecuted upon his confession.
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