Miller v. Fenton, 796 F.2d 598 (3d Cir. 1986)

Facts

Margolin was approached by a man who told her there was a loose heifer.  Margolin drove to the end of the driveway and did not return, found the next day in a creek.  A description was given of the man and his vehicle, which pointed to Miller.  Miller was interrogated for approximately an hour when he confessed to the crime.

Procedural History

Miller moved to suppress his confession as involuntary and the trial court denied the motion.

Issue(s)

Did the trial court err in denying Miller’s motion, finding that his confession was voluntary?

Holding(s)

No.

Reasoning/Analysis

The Court found that when evaluating the voluntariness of a confession, the court must consider the totality of the circumstances, looking at factors such as age, education, lack of advice, length of detention, nature of questioning, and use of physical punishment.  When evaluating these factors, the confession given by Miller was voluntary.  Although Boyce’s promises of psychiatric help and statements that Miller was not a criminal may have been a form of trickery, they are not dispositive on the totality of the circumstances analysis.

Judgment/Outcome

The Court affirmed the judgment of the trial court.

Concurring Opinions/Dissenting Opinions/Comments

Gibbons dissented, finding that the friendliness of Boyce, in combination with the trickery, made the interrogation inherently coercive.  Gibbons also felt Miller’s history of mental illness and 9^th grade education were important factors that majority overlooked.