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Colorado V. Connelly Law Case

Facts:

1. Connelly approached a police officer and showed interest on confessing about a murder that he committed.
2. Connelly had a history of mental illness and had been of his medication for at least 6 months.
3. Before Connelly made a confession, the officer gave Connelly his Miranda warnings and called a detective that before interrogating him, read him again his Miranda warnings.
4. Connelly acknowledge the understanding of his Miranda rights and confessed that he murder a young girl.
5. The next morning Connelly was disoriented and claimed that voices made him confess to the murder.
6. Connelly then was diagnosed by a psychiatrist with schizophrenia and wanted to suppress the use of his statements in court because his psychotic condition made him confess but he was able to understand his Miranda rights.

Procedural History:

• Supreme court of Colorado suppressed the evidence
• U.S Supreme Court

 Law:

“No person shall be held to answer for a capital, or otherwise infamous crime, unless on a presentment or indictment of a Grand Jury, except in cases arising in the land or naval forces, or in the Militia, when in actual service in time of War or public danger; nor shall any person be subject for the same offense to be twice put in jeopardy of life or limb; nor shall be compelled in any criminal case to be a witness against himself, nor be deprived of life, liberty, or property, without due process of law; nor shall private property be taken for public use, without just compensation.”

-5^th amendment

All persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States and of the state wherein they reside. No state shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States; nor shall any state deprive any person of life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws.

-14^th amendment

Legal Question:

1. Can Connelly’s statement be suppressed, since he made it in a state of mind in which he was not aware of the situation and the consequences? Holding and vote: No (7-2)
2. Reasoning: (Rehnquist, majority) joined by White, Blackmun, Powell, Stevens, O’Connor and scalia. The admissibility of statements is governed by state rules of evidence, rather than previous supreme court decisions regarding coerced confessions and Miranda waivers.
3. The officers did not use any questionable methods to get a confession from Connelly, in fact they told him that he had the right to remain silent, yet he proceeded to confess.
4. Similar cases in which statements were suppressed due to the defendant’s mental state is because the officers exploited their mental health to get a confession. I.e  Blackburn v. Alabama, 361 U. S. 199 (1960), and Townsend v. Sain, 372 U. S. 293 (1963)
5. The due process clause of the 5^th and 14^th amendment was not violated because the defendant did everything voluntarily and somewhat knowingly because schizophrenia does not impairs comprehension.
6. Voluntary in the eyes of the law means, not being influenced by an external force, in this case the defendant was not influenced by any police officer.

Concurring Opinion: (Blackmun and Stevens)

• Justice Blackmun agrees with everything, except with part III A, where it was talked about the defendant waived his Miranda rights. He believes that it was unnecessary.
• Justice Stevens believes that Connelly’s statement were involuntary. However the fifth amendment was not violated, therefore, it is not required to suppress the evidence gathered by the officers.

Dissenting opinion: (Justice Brennan joined by Marshall)

Justice Brennan believe that the defendant did not made this confessions in the right state of mind because of his condition and his withdrawal from medication for a prolonged period of time. He also believe that his hallucination had some effect in his ability to comprehend his Miranda rights. The absence of police misconduct does not necessarily means that the confessions was made on free will. The court has reversed similar cases in which a person confessed to a crime due to medication (Townsend v. Sain,372 U. S. 293, 1963). Allowing to include mentally ill individual to voluntary confession is an error because more often than not this confessions are going to be unreliable