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Colorado v. Connelly

Supreme Court of the United States · 1986 · Criminal Procedure

Criminal ProcedureConfessionsMirandaDue Processinvoluntary confessiondue processpolice coercionstate action

Facts

Connelly approached a Denver police officer and, without prompting, said he had murdered someone and wanted to talk about it. He was advised of his Miranda rights twice, said he understood them, and confessed in detail, including directing officers to the scene of the killing; the officers observed no indication of mental illness during the encounter. The next day, Connelly said that "voices" had told him to come to Denver and confess, and a psychiatrist later testified that Connelly suffered from chronic schizophrenia and command hallucinations that impaired his volitional abilities but did not significantly impair his cognitive abilities. The trial court found no police wrongdoing or coercion, but suppressed the statements as involuntary and found the Miranda waiver invalid because Connelly's illness destroyed his volition.

Issue

Does the Due Process Clause require suppression of a confession solely because the defendant's mental illness interfered with his rational intellect or free will, absent coercive police conduct? Also, what burden of proof governs the State's showing of a Miranda waiver, and does a defendant's mental condition alone render a waiver involuntary in the constitutional sense?

Rule

A confession is not involuntary within the meaning of the Due Process Clause absent coercive police activity causally related to the confession. The Constitution does not require courts to suppress statements solely because the defendant's mental condition may have affected their reliability or motivation; those matters are left to state evidentiary law. When the State must prove a Miranda waiver at a suppression hearing, it need prove waiver only by a preponderance of the evidence, and the voluntariness of waiver depends on the absence of police overreaching, not on free will in a broader sense.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Portland, Oregon, Nolan Pierce walked into a precinct lobby and told Officer Jenna Ruiz that he had set a warehouse fire months earlier. Ruiz immediately advised him of his rights, and Nolan said he understood and wanted to explain; later psychiatric evidence showed he had severe schizophrenia and believed invisible forces ordered him to confess, but the officers neither threatened nor pressured him.

If Nolan moves to suppress the confession under the Fourteenth Amendment Due Process Clause, how should the court rule?

Explanation. The majority held that a confession is not involuntary within the meaning of the Due Process Clause absent coercive police activity causally related to the confession. Mental illness may explain why the defendant spoke, but mental condition alone does not establish constitutional involuntariness. Reliability concerns are left to state evidentiary law, not the federal Due Process Clause.