479 U.S. 157, 107 S. Ct. 515, 93 L. Ed. 2d 473 (1986)
Respondent Francis Connelly approached Officer Patrick Anderson of the Denver Police Department on August 18, 1983, at approximately 2:40 p.m. and stated that he had killed someone and wanted to talk about it.1 Anderson immediately advised respondent of his Miranda rights.2 Respondent stated that he understood those rights but wanted to talk about the murder anyway.3
At this point, respondent stated that he had come all the way from Boston to confess to the murder of Mary Ann Junta, a young girl whom he had killed in Denver sometime during the month of November 1982.4 Respondent was then taken to police headquarters.5 A detective again advised him of his rights.6 After respondent answered that he understood them, he was asked to describe the murder in detail.7
Respondent gave a lengthy account including the location of the body, the date of the murder, the fact that he had used a blunt instrument in the killing, and that after killing the victim he had washed his knife in a nearby stream.8 After hearing this account, the detective arrested respondent for the murder of Mary Ann Junta.9 A search of the area where respondent said the body was located revealed the body of a young girl. The cause of death was determined to be a skull fracture.10
At a preliminary hearing, the psychiatrist who had examined respondent testified that at the time of the confession, respondent was clearly suffering from chronic schizophrenia and was in a psychotic state at least as of the time of his arrest.11 The psychiatrist testified that respondent's psychosis motivated his confession, that respondent was not capable of making a free and intelligent decision to confess, and that the confession was not voluntary.12 The trial court found that respondent's initial statement to Officer Anderson was involuntary and ordered that it be suppressed.13 The trial court also ruled that the subsequent statements made at the police station were tainted by the prior involuntary statement and ordered that they too be suppressed.14 The Colorado Supreme Court affirmed the suppression order.15
The United States Supreme Court granted certiorari to decide whether respondent's confession was obtained in a manner that violated the Due Process Clause.16
Whether the Due Process Clause requires suppression of a confession motivated by a defendant's mental illness in the absence of police coercion?17
Coercive police activity is a necessary predicate to a finding that a confession is not voluntary within the meaning of the Due Process Clause of the Fourteenth Amendment.18 A defendant's mental condition may be a significant factor in the voluntariness calculus, but by itself and apart from its relation to official coercion it does not dispose of the inquiry into constitutional admissibility.19
No. The ESTABLISHED FACTS show that respondent approached Officer Anderson voluntarily at approximately 2:40 p.m. on August 18, 1983, stated without prompting that he had killed someone, received Miranda warnings from Anderson and later from the detective, and repeatedly indicated that he understood those rights before providing details of the murder.20 The facts contain no evidence that any officer engaged in coercive conduct, exploited respondent's condition, or even knew of his mental illness.21 Although the psychiatrist testified that respondent's chronic schizophrenia and psychotic state motivated the confession and prevented a free and intelligent decision, the absence of any police misconduct means the confession was not constitutionally involuntary.22
The Due Process Clause does not require suppression of respondent's confession.23
Related opinions on this issue
Justice Blackmun concurred in the judgment because the confession was not the product of police coercion and therefore did not violate due process.24 He declined to join the Court's broader suggestion that mental illness can never be relevant to voluntariness absent police misconduct.25 In some circumstances a defendant's mental condition may be so severe that it renders him incapable of making a rational decision even in the absence of any police overreaching.26
But this is not such a case and he therefore concurred in the judgment.27
Joined by Justice Marshall
Justice Brennan dissented on the ground that the Due Process Clause prohibits admission of confessions that are not the product of a rational intellect and a free will.28 He emphasized that when a defendant's mental illness is as severe as respondent's and clearly motivates the decision to confess the confession cannot be considered voluntary in any meaningful sense regardless of the absence of overt police coercion.29 The totality of the circumstances must govern admissibility under established precedent.30
Whether a defendant's mental condition by itself can render a Miranda waiver invalid without police overreaching?31
A waiver of Miranda rights must be voluntary in the sense that it is the product of a free and deliberate choice rather than intimidation, coercion, or deception, and must be made with full awareness of the nature of the right and the consequences of abandoning it.32 The sole concern of the Fifth Amendment is governmental coercion; mental illness alone, without police overreaching, does not invalidate a waiver.33
No. The ESTABLISHED FACTS establish that both the police officer and the detective advised respondent of his Miranda rights, that respondent stated he understood them, and that he then provided a detailed account of the murder.34 The psychiatrist's testimony indicated only that respondent's psychosis motivated the confession and that he was incapable of a free and intelligent decision, but the facts show no police knowledge of any mental illness and no coercive tactics.35 Because the waiver inquiry focuses exclusively on the absence of governmental coercion, respondent's mental condition by itself did not render the waiver invalid.36
A defendant's mental condition by itself cannot render a Miranda waiver invalid without police overreaching.37
Related opinions on this issue
Justice Stevens joined Justice Brennan's dissent but wrote separately to distinguish precustodial from postcustodial statements.38 He accepted the trial court's finding that the initial statements were involuntary yet concluded they did not violate the Fifth Amendment because they were not the product of state compulsion.39 He would have held that respondent was not competent to waive his rights once custody began because the waiver was not the product of a free and deliberate choice.
Whether the prosecution must prove a Miranda waiver by clear and convincing evidence rather than by a preponderance of the evidence?40
Whenever the State bears the burden of proof in a motion to suppress a statement claimed to have been obtained in violation of Miranda, the State need prove waiver only by a preponderance of the evidence.41 The voluntariness determination is designed to detect police coercion and is not tied to the reliability of the verdict, so a higher standard is not required.42
No. The ESTABLISHED FACTS contain no indication that the Colorado courts applied an erroneous burden; rather, the Supreme Court of Colorado's suppression rested on its view that mental illness alone could invalidate the waiver.43 The governing rule requires only that the prosecution establish waiver by a preponderance of the evidence, and the facts show that both officers testified respondent appeared to understand the rights he was advised of, satisfying that standard in the absence of any police coercion.44
The prosecution need prove a Miranda waiver only by a preponderance of the evidence.45
Related opinions on this issue
Joined by Justice Marshall
Justice Brennan dissented from the holding that the government may establish a Miranda waiver by only a preponderance of the evidence.46 He argued that the explicit command of Miranda imposes a heavy burden on the government to demonstrate that the defendant knowingly and intelligently waived his privilege against self-incrimination and his right to retained or appointed counsel.47 This Court has always set high standards of proof for the waiver of constitutional rights.48
The constitutional ideal of excluding involuntary confessions deserves the highest standard of proof beyond a reasonable doubt especially once the Court redefined voluntariness to admit confessions not resulting from police wrongdoing.49 The lower standard risks admitting more involuntary confessions and undermines the values the exclusionary rule protects.50