Colorado v. Connelly Case Brief
United States Supreme Court
479 U.S. 157 (1986)
ISSUE: Was a confession voluntarily given if D blurted it out to police officers who did not coerce him at all all but it later turns out that D was suffering from psychosis?
HOLDING: Yes, coercive police activity is a necessary predicate to the finding that a confession is not "voluntary" within the meaning of the DPC.
- D approached an officer and told him that he wanted to confess to a murder
- The officer advised him of his rights but D wished to continue; another officer arrived and advised him of his rights as well
- D then took the officers to the scene of the murder and pointed out the exact location of the murder
- The next day, D said that "voices" told him to come to Colo. from Boston to confess that the he has followed their directions in so confessing
- Psychiatrist testified that D's psychosis motivated his confession
- Trial court suppressed the confession as involuntary
- Sup. Ct. affirmed
- No due process claim: Absent police conduct causally related to the confession, there is simply no basis for concluding that any state actor has deprived a criminal D of due process of law
- Need an element of police overreaching
- State of mind not dispositive: While mental condition is surely relevant to an individual's susceptibility to police coercion, mere examination of the confessant's state of mind can never conclude the due process inquiry
- Exclusionary rule inappropriate: The purpose of the excluding evidence seized in violation of the Constitution is to substantially deter future violations of the Constitution, but that is inapplicable where no police conduct is at issue
- A mentally ill person's involuntary confession is antithetical to the notion of fundamental fairness embodied in the DPC
- That all prior cases have involved police overreaching only means that this is a case of first impression
- Minimum standards of due process should require that the trial court find substantial indicia of reliability on the basis of evidence extrinsic to the confession itself before admitting the confession of a mentally ill person
- Connelly presents and interesting situation: can a confession violate the Due Process Clause if it was not obtained through misconduct by the police but was still "involuntary?" The answer, which may be surprising at first, is no. For a confession to be invalidated as obtained in violation of the Due Process Clauses of the Fifth and Fourteenth Amendments, it was be the result of police misconduct, i.e., something the police did and something that was misconduct.
- Here's a fact pattern you might see on a law school exam. Billy is arrested and taken to the police station where he is put in a nicely-decorated, evenly-lit, ventilated interrogation room with a large window. Billy's mom, hearing the Billy was arrested, marches down to the police station and runs into the interrogation room. Before Office Dogood can even say one word to Billy, Billy's mom starts furiously screaming at Billy and smacking him. "You tell the police what you did right this second, Billy! I'm sick of fixing your messes. Time to face the music, mister!" Dazed, Billy confesses to the police. Is Billy's confession a due process violation?
- No. Remember that in order for a confession to violate the Due Process Clause, it must have been obtained as the result of police misconduct. In our hypo, it was Billy's mom, not the police, that forced Billy to confess. Billy's mom's action might have been misconduct, but that's irrelevant for the due-process inquiry. Second, even though the police arrested Billy and took him into an interrogation room, nothing they did was "misconduct." They presumably acted lawfully at each step of the way. If this doesn't quite make sense yet, read the next bullet.
- So why the requirement of "police misconduct?" Well, the Supreme Court was and is concerned with "black police practices" in obtaining confessions. If a confession is involuntarily obtained but not involuntary because of something the police themselves did, then excluding that confession from the prosecution's case-in-chief won't achieve any goals of eliminating such black practices. The same holds true for Connelly where the defendant's own mental illness caused him to blurt out his confession. The police did nothing wrong, so why punish them? That's the logic anyways.