Supreme Court of the United States · 1986 · Criminal Procedure
Criminal ProcedureConfessionsRight to Present a DefenseSixth AmendmentFourteenth Amendmentconfessionvoluntarinesscredibility
Facts
Petitioner, a 16-year-old, confessed during police interrogation to the murder for which he was later tried. Before trial, the court held a suppression hearing, found the confession voluntary, and denied suppression despite petitioner's testimony that he had been held in a windowless room for a prolonged period, surrounded by officers, denied contact with his mother, and badgered into confessing. At trial, the prosecution's case rested almost entirely on the confession and the statement of petitioner's uncle, while the defense sought to show the confession was unworthy of belief because of both internal inconsistencies and the circumstances in which it was obtained. The trial court ruled that testimony about the duration and setting of the interrogation related only to voluntariness and excluded it from the jury.
Issue
Whether a state court violates the Sixth and Fourteenth Amendments by excluding testimony about the physical and psychological circumstances of a confession on the ground that those facts relate only to voluntariness, after the judge has already found the confession voluntary. More specifically, the question is whether a defendant may present such evidence to the jury to challenge the confession's credibility.
Rule
Evidence concerning the manner and circumstances in which a confession was obtained may be relevant not only to the legal question of voluntariness but also to the factual question of the confession's credibility and weight. Absent a valid state justification, the blanket exclusion of competent, reliable, and potentially exculpatory evidence central to the defendant's claim of innocence violates the constitutional right to a meaningful opportunity to present a complete defense under the Sixth and Fourteenth Amendments.
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In Phoenix, Diego Morales was charged with armed robbery after police introduced his signed confession. Before trial, the judge held a suppression hearing, found the confession voluntary, and denied suppression. At trial, Diego sought to call two officers to describe that he was questioned for 11 hours overnight in a cramped interview room by rotating teams of detectives, arguing this made the confession unreliable. The judge excluded all such testimony because voluntariness had already been decided.
Was the exclusion proper?
Explanation. The exclusion was improper. The majority held that the circumstances surrounding a confession may bear on two different questions: the legal issue of voluntariness for the judge and the factual issue of credibility and weight for the jury. A prior voluntariness ruling does not bar the defendant from presenting competent, reliable evidence about interrogation conditions to argue that the confession is unworthy of belief. The Constitution guarantees a meaningful opportunity to present a complete defense, and a blanket exclusion of central exculpatory evidence without valid justification violates that right. Trial courts still retain latitude to exclude repetitive or marginal evidence, so choice 4 is too broad. (Derived from Crane v. Kentucky (1986).)