Nature of Case
Whether a confession is still considered voluntary when it is prompted by a mental illness.
Facts of Case
Following the “voice of God,” Francis Connelly flew from Boston to Denver and on August 18, 1983, he approached a police officer in downtown, Denver. He stated that he murdered someone and wanted to discuss it. He was read his Miranda rights, but reported he still wanted to talk about the murder. He explained how he had murdered a young girl in 1982 and he then took the police to the scene of the crime. His command auditory hallucinations had told him to confess or commit suicide. He was initially found incompetent to stand trial. Six months later he was found competent. While the trial court found that the police had done nothing wrong or coercive when obtaining Connelly’s confession, the court still decided the initial statements and custodial confession needed to be suppressed because they were “involuntary.” The court said Connelly’s Constitutional rights were violated, because his mental state at the time of his confession interfered with his “rational intellect” and “free will.” Therefore, his mental condition precluded him from waiving his right to counsel and waiving his right against self-incrimination. The court held that the State had not proven the waiver by clear and convincing evidence. The Colorado Supreme Court affirmed the trial court’s decision and said that the test for admissibility was whether the statements made were “the product of a rational intellect and free will.” They decided his mental illness compelled him to confess. The United States Supreme Court granted certiorari, because it believed that the Colorado Supreme Court’s ruling conflicted with prior holdings of the United States Supreme Court.
Did the Colorado Supreme Court err in affirming the trial court’s decision and suppressing Connelly’s statements and custodial confession on the grounds that they were “involuntary?” Did the Colorado Supreme Court err in requiring a clear and convincing burden of proof for a Miranda waiver?
Justice Rehnquist delivered the opinion of the court. In a 7 to 2 decision, the Court held that Due Process Clause of the 14th Amendment requires “coercive police activity” in order to find a confession not “voluntary.” While mental condition can be a part of the voluntariness assessment, in the absence of official coercion it is irrelevant. Therefore, the Court concluded that taking the statements and allowing them into evidence did not violate the defendant’s due process rights. The Court said that the state laws governing admission of evidence should identify whether the confession is unreliable, and therefore, inadmissible. The Court concluded that the Colorado Supreme Court erred in requiring a clear and convincing standard, because the waiver should be only by a preponderance of the evidence. Furthermore, the Court stated that the Colorado Supreme Court erred in requiring “free will” in the Miranda waiver, as “free will has no place in this area of constitutional law.” The waiver must be made “knowingly, intelligently, and voluntarily,” but the voluntariness is in strict relation to police misconduct and not the defendant’s mental state. The court reversed the Colorado Supreme Court’s decision and remanded for further proceedings.
The Court concluded that in the absence of police coercion, the Due Process Clause does not cover perceived coercion due to mental state. Also, suppressing the statements would not serve in enforcing Constitutional rights. “The purpose of excluding evidence seized in violation of the Constitution is to substantially deter future violations of the Constitution.” The Court stated, “Only if we were to establish a brand new constitutional right- the right of a criminal defendant to confess to his crime only when totally rational and properly motivated-could respondent’s present claim be sustained.” Furthermore, it would be flawed to expand the “voluntariness” requirement to include a determination of the motivation for confessing, despite no claim of government misconduct.