Colorado Petitioneer V. Francis Barry Connelly Case Summary

Case Brief
Colorado Petitioner v. Francis Barry Connelly was a case appealed on October 8, 1986 by the Supreme Court of Colorado and later decided on December 10th, 1986 by the U.S. Supreme Court. The case began in Denver when, without any prompting, Francis Connelly approached police officer Patrick Anderson and claimed he had murdered a young girl named Mary Ann Junta. Before hearing anymore details, Officer Anderson immediately advised Connelly of his Miranda rights. The respondent said that he understood his rights but still wanted to discuss the murder. Officer Anderson asked Connelly several questions, where he denied drinking and taking drugs, but had claimed to be treated for mental illness. Soon after, detective Antuna arrived and Connelly was once again advised of his rights. Connelly claimed that

he had traveled from Boston to confess and was taken into custody. In custody, Connelly shared details about the murder and took officers to the scene of the crime giving them enough evidence to take him to court. Connelly was held overnight and while being interviewed the next morning, became visibly disoriented and stated that “voices” in his head convinced him to confess to the murder. Connelly was sent to a state mental hospital where he was found to have been suffering from chronic schizophrenia and had been in a psychotic state since the day before his confession. According to his psychiatrist, Connelly was found to have experienced command hallucinations. He was following the “voice of God” convincing him to either confess or commit suicide, so he reluctantly approached the officer. All officers dealing with Connelly the night prior claimed that Connelly had shown no signs of mental illness. The trial court held that the prosecution failed to show that Connelly had voluntarily waived his rights and ruled that the confession and any evidence were inadmissible. The decision was appealed, and the Colorado Supreme Court held that even though there was no police misconduct, Connelly’s initial confession was involuntary. The court held that Connelly’s illness made him incompetent of waiving his right to counsel and privilege against self-incrimination and his confession and all evidence was suppressed.
The issue to be decided by the court was whether an individual diagnosed with an mental illness, or in Connelly’s case, paranoid schizophrenia, is competent to waive their Miranda rights, and if their confession is considered voluntary and admissible. The U.S Supreme Court later reversed and held that although the mental condition of the defendant is important when assessing voluntariness, it cannot make a confession “involuntary” under the fourteenth Amendment due process clause. The court also held that notions of free will is not a matter in the area of constitutional law, and the respondents perception of coercion from the “voice of god” isn’t a matter that the Federal law can deal with. The outcome from the Supreme Court was that it’s hard to distinguish whether a confession is voluntary and should be admissible based on other forms of coercion not coming from policy activity within the fourteenth amendment. Because there was no violation of Miranda Rights and no misleading into surrendering rights under the Fifth Amendment, it was concluded that the state, based on their own rules of evidence, has the discretion to decide if confessions are reliable or not. This decision would be based on state presence of clear and convincing evidence and not federal law. This case was important because it significantly changed the standard of voluntariness, and more factors were then considered to determine voluntariness than just the totality of circumstances.
Justice Blackburn concurred in all parts but thought that the discussion of the state’s burden of proof being shaped under Miranda v.

Arizona was not necessary to the decision. Justice Stevens both concurred and dissented in part of the judgments. Stevens claimed that recording the confession doesn’t mean it is involuntary or that it doesn’t follow the Due Process Clause. Stevens believed that Connelly’s incompetence to stand trial meant he could have been incompetent to waive his rights. Justices Brennan and Marshall dissented and also believed that Connelly’s mental state was a reasonable factor in determining the validity of his waiving of rights. They thought that a confession given by a defendant who is mentally ill is one not given under a clear state of mind and is not voluntary. Without his confession, officers would have never obtained valid evidence to convict him of murder. Due process requires independent collection of evidence that would contribute to a conviction. Since there was no police misconduct, the evidence gathered had to be because of Connelly’s free, voluntary, confession but he was not able to make an intellectual decision at that

time.
Discussion
One part of the test in this case for determining if confessions were voluntary was that all statements should be the product of free and unconstrained choice. Fundamental fairness requires that all statements be made voluntarily without officer coercion. The second test for this case is that all confessions are a product of rational thinking and free will. Even though there might not be police coercion, it does not make a statement involuntary. But, statements can be made involuntary when there are external pressures, such as mental illness.