''Colorado v. Connelly'', 479 U.S. 157 (1986), was a
U.S. Supreme Court
The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point o ...
case that was initiated by Francis Connelly, who insisted that his
schizophrenic episode rendered him
incompetent
Incompetence is the inability to perform; lack of competence; ineptitude.
Aspects of incompetence include:
*Administrative incompetence, dysfunctional administrative behaviors that hinder attainment of organization goals
*Incompetence (law), a p ...
, nullifying his waiver of his
Miranda rights
In the United States, the ''Miranda'' warning is a type of notification customarily given by police to criminal suspects in police custody (or in a custodial interrogation) advising them of their right to silence and, in effect, protection ...
.
Prior history
Francis Connelly approached a
Denver police officer and expressed interest in talking about a murder that he committed. After being read his rights, Connelly continued to want to confess to the murder, so a detective was called. The detective repeated Connelly's rights again, but Connelly remained willing to discuss the murder. Connelly then waived his
right to counsel
In criminal law, the right to counsel means a defendant has a legal right to have the assistance of counsel (i.e., lawyers) and, if the defendant cannot afford a lawyer, requires that the government appoint one or pay the defendant's legal exp ...
, and described the details of the murder.
Soon afterwards, the court determined that Connelly was not of sound enough mind to stand trial, and was given six months of therapy. After the six months was completed, Connelly stood trial. During the trial, the
psychiatrist that evaluated Connelly testified that he believed that God told him to confess to the murder, or commit suicide. The lower court ruled that Connelly's waiver of his Miranda rights was made when he was incompetent due to his mental illness, so the confession of Connelly was not permitted in court.
The case then went to the
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.
Powers and duties
Appellate jurisdiction
Discretionary appeals
The Court ...
, where the local court's decision was upheld. The evidence of Connelly's confession was suppressed under the
due process clause of the
Fourteenth Amendment to the United States Constitution.
Case
The Supreme Court heard the case, and decided that Connelly's confession should not have been suppressed, due to a specific sentence in ''
Miranda v. Arizona
''Miranda v. Arizona'', 384 U.S. 436 (1966), was a landmark decision of the U.S. Supreme Court in which the Court ruled that the Fifth Amendment to the U.S. Constitution restricts prosecutors from using a person's statements made in response to ...
'' 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.
[Bloom & Brodin, Criminal Procedure (Aspen 1996) at 247.] 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.
See also
*
List of United States Supreme Court cases, volume 479
This is a list of all the United States Supreme Court cases from volume 479 of the ''United States Reports
The ''United States Reports'' () are the official record ( law reports) of the Supreme Court of the United States. They include ruling ...
*
List of United States Supreme Court cases
This page serves as an index of lists of United States Supreme Court cases. The United States Supreme Court is the highest federal court of the United States.
By Chief Justice
Court historians and other legal scholars consider each Chief J ...
*
Lists of United States Supreme Court cases by volume
The following is a complete list of cases decided by the United States Supreme Court organized by volume of the ''United States Reports'' in which they appear. This is a list of volumes of ''U.S. Reports'', and the links point to the contents of e ...
*
*
Exclusionary rule
In the United States, the exclusionary rule is a legal rule, based on constitutional law, that prevents evidence collected or analyzed in violation of the defendant's constitutional rights from being used in a court of law. This may be consider ...
References
Further reading
*
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External links
* {{caselaw source
, case = ''Colorado v. Connelly'', {{ussc, 479, 157, 1986, el=no
, courtlistener =https://www.courtlistener.com/opinion/111779/colorado-v-connelly/
, findlaw = https://caselaw.findlaw.com/us-supreme-court/479/157.html
, justia =https://supreme.justia.com/cases/federal/us/479/157/
, loc =http://cdn.loc.gov/service/ll/usrep/usrep479/usrep479157/usrep479157.pdf
, oyez =https://www.oyez.org/cases/1986/85-660
United States Supreme Court cases
United States Supreme Court cases of the Rehnquist Court
Miranda warning case law
Insanity-related case law
1986 in United States case law
1986 in Colorado
Legal history of Colorado
Schizophrenia
History of Denver