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Colorado v. Connelly | 479 U.S. 157 (1986)
If the voices in your head tell you to confess to murder, does that mean your confession is involuntary? That was the question in Colorado versus Connelly.
One August night, Francis Connelly approached a Denver police officer and announced that he wanted to confess to a murder. The officer informed Connelly of his Miranda rights. Connelly said he understood those rights, but still wanted to confess. He denied that he’d been drinking or taking drugs. He said he’d previously been hospitalized for mental illness but felt fine that night. Later that night, Connelly met a homicide detective, who again advised him of his rights. Connelly told him that he’d killed a girl in Denver the previous fall. He described the event in detail, and then took the detective to the exact location where an unidentified female body had been found a few months earlier. The detective saw no indication that Connelly was suffering from mental illness.
The next day, however, Connelly seemed disoriented, and claimed that voices had told him to come to Denver to confess. The police sent him to a hospital, where he was diagnosed with schizophrenia and deemed too psychotic to assist in his own defense. After six months of treatment, doctors pronounced him competent to stand trial.
At a preliminary hearing, Connelly moved to suppress his statements on the ground that he was psychotic when he approached the police in Denver, and he thought the voice of God was telling him to confess. Doctors testified that Connelly’s cognitive abilities had been intact and he understood his rights, but that the voices had interfered with his ability to make free and rational choices. The trial court decided that Connelly’s statements should be suppressed because they were involuntary.
The Colorado Supreme Court affirmed, holding that the correct test for admissibility was whether statements are the product of a rational intellect and free will, both of which can be undermined by mental illness even without any external pressure. It found that Connelly’s waiver of his Miranda rights was invalid due to his mental illness. Even without police coercion, his confession was involuntary under the Due Process Clause of the Fourteenth Amendment. The United States Supreme Court granted certiorari.
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