Colorado v. Connelly
Encyclopedia
Colorado v. Connelly, , was a U.S. Supreme Court
case that was initiated by Francis Connelly, who insisted that his schizophrenic episode
rendered him incompetent, nullifying his waiver of his Miranda rights.
, and described the details of the murder.
Soon afterwards, the court determined that Mr. Connelly was not of sound enough mind to stand trial, and was given six months of therapy. After the six months was completed, Mr. Connelly stood trial. During the trial, the psychiatrist
that evaluated Mr. Connelly testified that he believed that God told him to confess to the murder, or commit suicide. The lower court ruled that Mr. Connelly's waiver of his Miranda rights was made when he was incompetent due to his mental illness, so the confession of Mr. Connelly was not permitted in court.
The case then went to the Colorado Supreme Court
, where the local court's decision was upheld. The evidence of Mr. Connelly's confession was suppressed under the due process clause of the Fourteenth Amendment to the United States Constitution
.
that stated that confessions may only be thrown out if the accused is coercively interrogated by the government. The Supreme Court reversed the Colorado Supreme Court's decision to suppress the evidence, stating that there was no violation of the due process clause. In the words of the Supreme Court:
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...
case that was initiated by Francis Connelly, who insisted that his schizophrenic episode
Schizophrenia
Schizophrenia is a mental disorder characterized by a disintegration of thought processes and of emotional responsiveness. It most commonly manifests itself as auditory hallucinations, paranoid or bizarre delusions, or disorganized speech and thinking, and it is accompanied by significant social...
rendered him incompetent, nullifying his waiver of his Miranda rights.
Prior history
Francis Connelly approached a police officer and expressed interest in talking about a murder that he committed. After being read his rights, Mr. Connelly continued to want to confess to the murder, so a detective was called. The detective repeated Mr. Connelly's rights again, but Mr. Connelly remained willing to discuss the murder. Mr. Connelly then waived his right to counselRight to counsel
Right to counsel is currently generally regarded as a constituent of the right to a fair trial, allowing for the defendant to be assisted by counsel , and if he cannot afford his own lawyer, requiring that the government should appoint one for him/her, or pay his/her legal expenses...
, and described the details of the murder.
Soon afterwards, the court determined that Mr. Connelly was not of sound enough mind to stand trial, and was given six months of therapy. After the six months was completed, Mr. Connelly stood trial. During the trial, the psychiatrist
Psychiatrist
A psychiatrist is a physician who specializes in the diagnosis and treatment of mental disorders. All psychiatrists are trained in diagnostic evaluation and in psychotherapy...
that evaluated Mr. Connelly testified that he believed that God told him to confess to the murder, or commit suicide. The lower court ruled that Mr. Connelly's waiver of his Miranda rights was made when he was incompetent due to his mental illness, so the confession of Mr. Connelly was not permitted in court.
The case then went to the Colorado Supreme Court
Colorado Supreme Court
The Colorado Supreme Court is the highest court in the U.S. state of Colorado. Located in Denver, the Court consists of a Chief Justice and six Associate Justices.-Appellate jurisdiction:...
, where the local court's decision was upheld. The evidence of Mr. Connelly's confession was suppressed under the due process clause of the Fourteenth Amendment to the United States Constitution
Fourteenth Amendment to the United States Constitution
The Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments.Its Citizenship Clause provides a broad definition of citizenship that overruled the Dred Scott v...
.
Case
The Supreme Court heard the case, and decided that Mr. Connelly's confession should not have been suppressed, due to a specific sentence in Miranda v. ArizonaMiranda v. Arizona
Miranda v. Arizona, , was a landmark 5–4 decision of the United States Supreme Court. The Court held that both inculpatory and exculpatory statements made in response to interrogation by a defendant in police custody will be admissible at trial only if the prosecution can show that the defendant...
that stated that confessions may only be thrown out if the accused is coercively interrogated by the government. The Supreme Court reversed the Colorado Supreme Court's decision to suppress the evidence, stating that there was no violation of the due process clause. In the words of the Supreme Court:
Consequences
Connelly significantly changed the voluntariness standard - the test used to determine the admissibility of confessions under the due process clauses of the Fifth and Fourteenth Amendments. Before Connelly the test was whether the confession was voluntary considering the totality of the circumstances. "Voluntary" carried its everyday meaning: the confession had to be a product of the exercise of the defendant's free will rather than police coercion. After Connelly the totality of circumstances test is not even triggered unless the defendant can show coercive police conduct. Questions of free will and rational decision making are irrelevant to a due process claim unless police misconduct existed and a causal connection can be shown between the misconduct and the confession. *should be evaluated for bias*See also
- List of United States Supreme Court cases, volume 479
- 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
- Exclusionary ruleExclusionary ruleThe 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...