police interrogation

On August 5, 1999, Michael Crawford stabbed Kenneth Lee in the torso during a confrontation at Lee's apartment. Crawford and his wife Sylvia had gone there after Sylvia alleged that Lee had attempted to rape her several weeks earlier. Lee was taken to the hospital and later died from his wounds. Police arrested both Crawford and Sylvia that night. Detectives gave Miranda warnings and interrogated Sylvia twice at the station house. In her recorded statement Sylvia initially denied involvement but eventually admitted she had led Crawford to Lee's apartment and had seen the stabbing. Crawford also gave police a statement describing the events and his belief that Lee may have reached for something before the stabbing. At trial Crawford asserted self-defense, but Sylvia did not testify because of Washington's marital privilege. The State offered Sylvia's tape-recorded statement as evidence that the stabbing was not in self-defense and invoked the hearsay exception for statements against penal interest. The trial court admitted the statement after finding it bore particularized guarantees of trustworthiness. The jury convicted Crawford of assault. The Washington Court of Appeals reversed after applying a nine-factor test and concluding the statement lacked sufficient indicia of reliability. The Washington Supreme Court reinstated the conviction. It determined that Sylvia's statement interlocked with Crawford's statement and therefore bore adequate guarantees of trustworthiness, noting that both accounts were ambiguous on whether Lee had possessed a weapon. The United States Supreme Court granted certiorari.

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. Anderson immediately advised respondent of his Miranda rights. Respondent stated that he understood those rights but wanted to talk about the murder anyway. 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. Respondent was then taken to police headquarters. A detective again advised him of his rights. After respondent answered that he understood them, he was asked to describe the murder in detail. 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. After hearing this account, the detective arrested respondent for the murder of Mary Ann Junta. 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. 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. 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. The trial court found that respondent's initial statement to Officer Anderson was involuntary and ordered that it be suppressed. 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. The Colorado Supreme Court affirmed the suppression order. The United States Supreme Court granted certiorari to decide whether respondent's confession was obtained in a manner that violated the Due Process Clause.