Crane v. Kentucky, 476 U.S. 683 (1986)

In Crane v. Kentucky, 476 U.S. 683 (1986) the Supreme Court held that the defendant’s Fourteenth and Sixth Amendment rights to a fair trial were violated when the trial judge excluded testimony regarding the physical and psychological circumstances of a confession, based on the fact that a pretrial hearing had already been held on the issue of voluntariness of the confession.

Crane, at the age of sixteen, was questioned about the murder of a convenience store clerk and began voluntarily confessing to numerous past crimes and, after being moved to a formal interrogation facility, eventually confessed to the murder in question. The police had no physical evidence against Crane, only the confession. Crane sought to suppress his confession at trial, but the judge ruled the voluntariness issue had been addressed and could not be relitigated before a jury.

The Supreme Court had previously held in Sims v. Georgia, 385 U.S. 538 and Jackson v. Denno, 378 U.S. 368, that the circumstances surrounding the taking of a confession are ‘‘relevant to two separate inquiries, one legal and one factual.’’ How a confession is derived, such as the issue of voluntariness, is a matter of legality and was appropriately addressed during the pretrial hearing. In Crane, the Supreme Court held that the issue of the physical and psychological circumstances under which a confession was derived is relevant to the factual issue of innocence or guilt and must be allowed as a defense at trial in the presence of a jury.

JEANNINE M. EIBAND

Cases and Statutes Cited

• Jackson v. Denno, 378 U.S. 368
• Sims v. Georgia, 385 U.S. 538

See also Coerced Confessions/Police Interrogations; Defense, Right to Present