United States v. Carignan

Background

A man in Alaska was convicted of first-degree murder for an attempted rape after giving a written confession. He had first been detained, identified in a line-up, and committed on a separate assault charge that occurred six weeks after the murder. The Court of Appeals reversed the conviction because the confession was admitted under circumstances said to conflict with an earlier rule about prompt arraignment and detention.

Reasoning

The central question was whether that rule (often called the McNabb rule) automatically excludes a confession given while a person is lawfully detained on a different charge. The Court found a separate, reversible error: the trial judge refused to let the defendant testify outside the jury about whether his confession was voluntary. The Court therefore set aside the conviction for that reason. It also declined to extend the McNabb rule to bar confessions about other crimes when a person is lawfully held on a separate charge, emphasizing that voluntariness—not simply timing—remains the core test for admission.

Real world impact

The decision means judges must give defendants an out-of-jury chance to offer testimony about how a confession was obtained when admissibility is contested. Police will not automatically be barred from using statements made during lawful detention on unrelated charges, but those statements can still be excluded if they are shown to be involuntary. The case requires a new examination at retrial of whether this particular confession was truly voluntary.

Dissents or concurrances

A concurring opinion argued more forcefully that arrest on one charge should not be used as a device to investigate other crimes, urging a broader rule to prevent detention-from-investigation practices.