Colorado v. Connelly

Background

A man approached a uniformed police officer and said he had killed someone and wanted to talk. Before questioning, the officer read the man his Miranda rights. The man waived those rights and confessed to killing a young girl. At trial the man moved to suppress his statements, saying they were involuntary. A psychiatrist testified he suffered from chronic paranoid schizophrenia and “command auditory hallucinations” and believed God told him to confess or commit suicide. The trial court suppressed statements made both before and after the Miranda warnings. The Colorado Supreme Court affirmed that suppression.

Reasoning

The prosecutor asked this Court to review only the suppression of the man’s initial unsolicited statements and expressly excluded the later Miranda issue. Despite that, the Court directed the parties to brief whether the man’s mental condition made his Miranda waiver ineffective. Justice Brennan criticizes that action. He says the Court is effectively rewriting the prosecutor’s petition and appears to be helping prosecutors by expanding the issues to be decided. Brennan also notes a pattern of summary decisions favoring the prosecution and stresses that the Court should protect citizens’ rights. He does not express a view on the underlying merits of the confession claims.

Real world impact

Because the Court granted review on the Miranda-waiver question, defendants with serious mental illness may see additional scrutiny of their confessions. The order pauses final enforcement of the case while the Court acts. Brennan warns that the Court’s practice of broadening issues could make it harder for defendants and give the appearance of siding with prosecutors. This is a grant of review, not a final ruling, so the legal outcome could still change on full consideration.