Facts
Anderson was working off-duty when he was approached by Connelly, who confessed to a murder. Connelly was advised of his rights but he insisted on talking. Connelly was taken to the station, where records showed an unidentified murder was discovered 6 months after Connelly’s supposed murder. Connelly was held overnight and after being evaluated, it was determined he suffered from chronic schizophrenia.
Procedural History
Connelly moved to suppress his statements and the trial court granted the suppression, finding that the statements were involuntary. The Colorado Supreme Court affirmed, finding that the absence of police coercion does not foreclose a finding of involuntariness.
Issue(s)
Did the Colorado Supreme Court err in finding that even without police coercion, a statement can be deemed involuntary via the Due Process Clause?
Holding(s)
Yes.
Reasoning/Analysis
The Court found that absent police conduct causally related to the confession, there is simply no basis for concluding that any state actor has deprived a criminal defendant of due process of law. A defendant’s mental condition, by itself and apart from its relation to official coercion, should never dispose of the inquiry into constitutional voluntariness. The Supreme Court of Colorado also erred in importing into this are of constitutional law notions of free will that have no place there.
Judgment/Outcome
The Court reversed the judgment of the Colorado Supreme Court.
No comments:
Post a Comment