Arizona v. Fulminante
Encyclopedia
Arizona v. Fulminante, was a decision issued by the United States Supreme Court
clarifying the standard of review of a criminal
defendant's allegedly coerced confession
.
In 1982, the 11-year-old stepdaughter of one Oreste Fulminante was murder
ed in Arizona
. Later, Fulminante was incarcerated for an unrelated crime. While in prison, Fulminante met Anthony Sarivola, a fellow inmate, who was also a confidential informant
for the Federal Bureau of Investigation
. Sarivola offered Fulminante protection from "tough treatment" in prison in exchange for a confession to the murder of Fulminante's stepdaughter. Fulminante agreed, confessing to Sarivola that he murdered his stepdaughter. As a result, Fulminante was charged with the murder, and his confession to Sarivola was used against him at trial.
The trial court denied Fulminante's motion to suppress
the confession on the basis that it was coerced because Fulminante might have been subject to violence in prison had he not confessed. Fulminante was convicted and sentenced to death, and appealed to the Arizona Supreme Court
, which held that the confession was indeed coerced. Reasoning that a harmless error
analysis was inappropriate in the case of involuntary confessions, the court ordered a new trial.
In a divided opinion, the United States Supreme Court held that the state supreme court's finding that the threat of violence aimed at Fulminante was credible enough to establish a finding of coercion, and therefore affirmed the reversal. In addition, the Court held that a harmless error analysis should nonetheless be applied to any allegedly coerced confession. In either case, the Court held that a new trial was warranted.
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
clarifying the standard of review of a criminal
Crime
Crime is the breach of rules or laws for which some governing authority can ultimately prescribe a conviction...
defendant's allegedly coerced confession
Confession
This article is for the religious practice of confessing one's sins.Confession is the acknowledgment of sin or wrongs...
.
In 1982, the 11-year-old stepdaughter of one Oreste Fulminante was murder
Murder
Murder is the unlawful killing, with malice aforethought, of another human being, and generally this state of mind distinguishes murder from other forms of unlawful homicide...
ed in Arizona
Arizona
Arizona ; is a state located in the southwestern region of the United States. It is also part of the western United States and the mountain west. The capital and largest city is Phoenix...
. Later, Fulminante was incarcerated for an unrelated crime. While in prison, Fulminante met Anthony Sarivola, a fellow inmate, who was also a confidential informant
Informant
An informant is a person who provides privileged information about a person or organization to an agency. The term is usually used within the law enforcement world, where they are officially known as confidential or criminal informants , and can often refer pejoratively to the supply of information...
for the Federal Bureau of Investigation
Federal Bureau of Investigation
The Federal Bureau of Investigation is an agency of the United States Department of Justice that serves as both a federal criminal investigative body and an internal intelligence agency . The FBI has investigative jurisdiction over violations of more than 200 categories of federal crime...
. Sarivola offered Fulminante protection from "tough treatment" in prison in exchange for a confession to the murder of Fulminante's stepdaughter. Fulminante agreed, confessing to Sarivola that he murdered his stepdaughter. As a result, Fulminante was charged with the murder, and his confession to Sarivola was used against him at trial.
The trial court denied Fulminante's motion to suppress
Exclusionary rule
The exclusionary rule is a legal principle in the United States, under constitutional law, which holds that evidence collected or analyzed in violation of the defendant's constitutional rights is sometimes inadmissible for a criminal prosecution in a court of law...
the confession on the basis that it was coerced because Fulminante might have been subject to violence in prison had he not confessed. Fulminante was convicted and sentenced to death, and appealed to the Arizona Supreme Court
Arizona Supreme Court
The Arizona Supreme Court is the state supreme court of the U.S. state of Arizona. It consists of a Chief Justice, a Vice Chief Justice, and three associate justices. Each justice is appointed by the governor of Arizona from a list recommended by a bipartisan commission. Justices stand for...
, which held that the confession was indeed coerced. Reasoning that a harmless error
Harmless error
A harmless error is a ruling by a trial judge that, although mistaken, does not meet the burden for a losing party to reverse the original decision of the trier of fact on appeal, or to warrant a new trial. Harmless error is easiest to understand in an evidentiary context...
analysis was inappropriate in the case of involuntary confessions, the court ordered a new trial.
In a divided opinion, the United States Supreme Court held that the state supreme court's finding that the threat of violence aimed at Fulminante was credible enough to establish a finding of coercion, and therefore affirmed the reversal. In addition, the Court held that a harmless error analysis should nonetheless be applied to any allegedly coerced confession. In either case, the Court held that a new trial was warranted.
In Popular Culture
Interpretation of the Fulminante Decision is a major plot element in the Law & Order episode "Confession" TV.com Summary of Law & Order "Confession"See also
- List of United States Supreme Court cases, volume 499
- List of United States Supreme Court cases
- Lists of United States Supreme Court cases by volume
- List of United States Supreme Court cases by the Rehnquist Court
- Chapman v. California,
- Premo v. MoorePremo v. MoorePremo, Superintendent, Oregon State Penitentiary v. Moore was a 2011 United States Supreme Court case involving the right of individuals to federal habeas corpus relief on state-law claims...
, (2011)