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Colorado v. Connelly 479 U.S. 157 (1986) Case Brief...

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Case Brief #1 Colorado v. Connelly 479 U.S. 157 (1986) CRJS 475-007 September 30, 2017

Colorado v. Connelly 479 U.S. 157 (1986)

PART I: CASE BRIEF

Facts of the Case: Colorado v. Connelly 479 U.S. 157 (1986) COLORADO, Petitioner v. Francis Barry CONNELLY. No. 85–660 was argued Oct. 8, 1986 and Decided Dec. 10, 1986. This case was held was held in the The United States Colorado Supreme Court 702 P.2d 722. This case was initiated by Francis Barry Connelly. This case was initiated by Connelly after he confessed to a murder and then argued that he was incompetent due to his mental illness, schizophrenia. The event took place as follows, Francis Connelly approached an off duty police officer and told the officer that he murdered somebody and wanted to talk about it. The officer advised the Respondent of his Miranda rights. The Respondent responded by saying that he understood these rights and wishes to continue talking about the murder. Connelly informed the officer about past mental instability, however, the officer felt as though Connelly was able to give a confession. Connelly confessed to the officers that he killed a young girl in Colorado in the past, he was then taken to the police station and also took officers to the scene of the crime. Note that during this time period Connelly exhibited no symptoms of mental illness. They held Connelly overnight at the station and he was interviewed by a public defender the next day. During this interview Connelly displayed symptoms of mental illness including disorientation, and hearing of voices. Connelly was sent to a mental hospital for evaluation and doctors cleared him to stand trial at a preliminary hearing. During this hearing Connelly revoked statements and a physician testified that Connelly was suffering from chronic schizophrenia and was in a psychotic state the day before he confessed. The Colorado trial court decided that

respondent’s statements must be suppressed because they were ‘involuntary.’ On appeal, the Supreme Court of Colorado affirmed, holding that the admission of the evidence in a court of law would have violated the Due Process Clause of U.S. Constitutional Amendment XIV. On certiorari, the Court reversed, holding that absent police coercion, defendant's confession was not barred by either Miranda or the Due Process Clause. Legal Question: The legal issue at question is whether or not the United States Constitution “requires a court to suppress a confession when the mental state of the defendant, at the time he made the confession, interfered with his ‘rational intellect’ and his ‘free will’”. Holding: The Due Process Clause of the Fourteenth Amendment Court states that coercive police activity is a necessary affirmation to the finding that a confession is not “voluntary”. This also concludes that the taking of Connelly’s statements and their admission into evidence, does not violate that clause. The majority further concluded that the state court was incorrect in finding that that “the State must bear its burden of proving waiver of these Miranda rights by ‘clear and convincing evidence”. The Supreme Court of Colorado was also wrong in “analysis of the question whether respondent had waived his Miranda rights in this case.”

Rationale:

The court's reasoning for their decision was decided with many different things being taken into account. For one the absence of the due process claim. There was no basis for concluding that any officer has deprived Connelly of due process of law. Secondly, Connelly’s state of mind was not “dispositive”. Examination of the Connelly’s state of mind can never conclude the “due process inquiry”. Lastly,the exclusionary rule was inappropriate. Police conduct was not an issue in this case.

Dissenting Opinion:

.Justice Blackmun filed an opinion concurring in part and concurring in the judgment. Justice Stevens filed an opinion concurring in the judgment in part and dissenting in part. Justice Brennan dissented and filed an opinion in which Justice Marshall joined. (479 U.S. 157, 107 S.Ct. 515, 93 L.Ed.2d 473, 55 USLW 4043)

Significance of this Case: This case emphasized the court's refusal to expand upon the protections a defendant enjoys under the Constitution because the suppression of this type of confession would not deter law enforcements’ misdeeds.

PART II: DISCUSSION

My personal opinion on this case outcome is in agreeance with decision. As stated earlier On appeal, the Supreme Court of Colorado affirmed, holding that the admission of the evidence in a court of law would have violated the Due Process Clause of U.S. Constitutional Amendment XIV. On certiorari, the Court reversed, holding that absent police coercion, defendant's confession was not barred by either Miranda or the Due Process Clause. The use of a mentally ill person’s involuntary confession is unethical to the notion of fundamental fairness embodied in Due Process. A true commitment to fundamental fairness requires that confessions be free and voluntary. The ensuring that the confession is voluntary is an independent concern of any issues relating to police coercion. I believe mental illness needs to be accounted for at all time. Oftentimes, I see people become convicted of crimes or become lost in the judicial system based on crimes they were convicted of and didn't necessarily do or had some mental illness that was not accounted for. I have to agree with the Colorado Supreme Court, where the local court's decision to dismiss Connelly's confession was upheld.

Literature Cited:

479 U.S. 157, 107 S.Ct. 515, 93 L.Ed.2d 473, 55 USLW 4043...