In Colorado v. Connelly, the Supreme Court explicitly held that police coercion was an indispensable element to a finding that a confession was ‘‘involuntary’’ under the Due Process Clause. The Court further held that the government need only establish wavier of Miranda rights under a preponderance of the evidence standard.
Defendant Connelly had approached a police officer and, without prompting, confessed to murdering someone. After receiving Miranda rights, the defendant elaborated on his confession, stating that he had killed a particular young woman in November of 1982. Police records confirmed that the body of an unidentified woman had been found several months later. The defendant then directed police officers to the crime scene.
The following day, while meeting with the public defender’s office, the defendant became confused and disoriented, stating that ‘‘voices’’ had driven him to confess. At a suppression hearing, a psychiatrist testified that the defendant was suffering from ‘‘command hallucinations’’ that interfered with his ability to make free choices. The state courts suppressed defendant’s statements on the basis that they were involuntary.
The Court reversed in an opinion authored by Chief Justice Rehnquist, holding that there could be no due process violation without some element of police overreaching. Because the police had nothing to cause the defendant’s confession, his statements should have been admitted. Justices Brennan and Marshall dissented, finding that the majority opinion denied the defendant the right to make an important choice with a ‘‘sane mind.’’
M. K. B. DARMER
References and Further Reading
Cases and Statutes Cited
See also Coerced Confessions/Police Interrogations; Miranda Warning