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Colorado v. Francis Connelly
Seal of the United States Supreme Court.svg
Argued October 8, 1986
Decided December 10, 1986
Full case name Colorado v. Francis Barry Connelly
Docket nos. 85-660
Citations 479 U.S. 157 (more)
107 S. Ct. 515; 93 L. Ed. 2d 473
Prior history People v. Connelly, 702 P.2d 722 (Colo. 1985); cert. granted, 474 U.S. 1050 (1986).
Holding
As Connelly was not coerced by the police to divulge any information, his confession was voluntary, and there was no violation of the Due Process Clause.
Court membership
Case opinions
Majority Rehnquist, joined by White, Powell, O'Connor, Scalia; Blackmun (except Part III–A)
Concurrence Blackmun
Concur/dissent Stevens
Dissent Brennan, joined by Marshall
Laws applied
U.S. Const. Amend. XIV

Colorado v. Connelly was an important case heard by the U.S. Supreme Court in 1986. It was about whether a confession could be used in court if the person confessing had mental health issues. Francis Connelly, the person involved, said his confession should not count because of his mental state. He also said he could not properly give up his Miranda rights.

The Story Before the Court

Francis Connelly walked up to a police officer in Denver. He told the officer he wanted to talk about a murder he had committed. The officer read Connelly his Miranda rights. These rights tell you that you have the right to remain silent and the right to an attorney.

Connelly's Confession

Even after hearing his rights, Connelly still wanted to confess. A detective was called to the scene. The detective also read Connelly his rights again. Connelly said he understood them and still wanted to talk. He then gave up his right to counsel, meaning he chose not to have a lawyer present. Connelly then described the details of the murder.

Court's First Decision

Soon after, a court decided that Connelly was not mentally well enough to stand trial. He was given six months of therapy to help him. After this time, Connelly was ready for trial. During the trial, a psychiatrist who had evaluated Connelly testified. The psychiatrist said that Connelly believed God had told him to confess to the murder.

The local court then made a decision. It ruled that Connelly's choice to give up his Miranda rights was not valid. This was because he was not mentally sound at the time. So, the court said Connelly's confession could not be used as evidence.

Colorado Supreme Court's Ruling

The case then went to the Colorado Supreme Court. This court agreed with the local court's decision. They said that Connelly's confession could not be used. They based this on the due process clause of the Fourteenth Amendment to the United States Constitution. This clause ensures that the government must respect all legal rights owed to a person.

The Supreme Court's Decision

The case eventually reached the U.S. Supreme Court. The Supreme Court looked at the case and made a different decision. They said that Connelly's confession should have been allowed in court.

Why the Confession Was Allowed

The Supreme Court pointed to a specific part of an earlier case, Miranda v. Arizona. This part said that confessions can only be thrown out if the police forced the person to confess. The Court found that the police did not force Connelly to talk. He approached them on his own.

The Supreme Court decided that there was no violation of the due process clause. They said that police actions must be "coercive" (meaning forceful or pressuring) for a confession to be considered involuntary. Connelly's mental state was a factor, but it wasn't enough on its own to make the confession invalid if the police didn't do anything wrong.

The Supreme Court explained it this way:

Coercive police activity is a necessary predicate to finding that a confession is not "voluntary" within the meaning of the Due Process Clause. Here, the taking of respondent's statements and their admission into evidence constituted no violation of that Clause. While a defendant's mental condition may be a "significant" factor in the "voluntariness" calculus, this does not justify a conclusion that his mental condition, by itself and apart from its relation to official coercion, should ever dispose of the inquiry into constitutional "voluntariness".

This means that for a confession to be thrown out, the police must have done something to force it. If the police did not act in a forceful way, then the confession can be used.

How This Case Changed Things

The Connelly case made a big change to something called the voluntariness standard. This standard is a test used to decide if a confession can be used in court. It relates to the Fifth and Fourteenth Amendments of the U.S. Constitution.

Before Connelly

Before this case, courts would look at all the circumstances around a confession. They would ask if the confession was truly "voluntary." This meant asking if the person confessed freely, without being forced by the police. The person's free will was the main focus.

After Connelly

After the Connelly decision, the rules changed. Now, to even question if a confession was voluntary, the person must first show that the police acted in a forceful or pressuring way. If there was no police misconduct, then the confession is generally considered voluntary.

This means that a person's mental state or ability to make a rational decision is not enough to throw out a confession. Unless the police did something wrong, and that wrong action caused the confession, it will likely be allowed in court.

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