Colorado v. Connelly

In Colorado v. Connelly, 479 U.S. 157 (1986), the defendant's statements to the police, after a waiver of Miranda rights, were deemed admissible notwithstanding the defendant's contention that it was the voice of God that told him to confess to the murder he had committed. Id. at 161. A psychiatrist gave expert opinion that the defendant was experiencing command hallucinations which interfered with his ability to make free and rational choices. Id. Despite this, the Court rejected an approach that would require a court to make "sweeping inquiries into the state of mind of a criminal defendant who has confessed, inquiries [that are] divorced from any coercion brought to bear on the defendant by the State." Id. at 166-167. The United States Supreme Court addressed a claim of an involuntary Miranda waiver because Connelly was "following the voice of God" in making his statements confessing to a murder. Id. at 161. Psychiatric testimony also revealed that Connelly was suffering chronic schizophrenia and was in a psychotic state around the time of his Miranda waiver and confession. Id. The Colorado Supreme Court suppressed the statements reasoning that, although police engaged in no overreaching, the statements were not a product of "rational intellect and a free will" and therefore were involuntary. Id. at 162. In reversing this reasoning, the United States Supreme Court held: We think that the Supreme Court of Colorado erred in importing into this area of constitutional law notions of 'free will' that have no place there. There is obviously no reason to require more in the way of 'voluntariness' inquiry in the Miranda waiver context than in the Fourteenth Amendment confession context. The sole concern of the Fifth Amendment on which Miranda was based, is governmental coercion. Indeed, the Fifth Amendment privilege is not concerned 'with moral and psychological pressures to confess emanating from sources other than official coercion.' The voluntariness of a waiver of this privilege has always depended on the absence of police overreaching, not on 'free choice' in any broader sense of the word. (The relinquishment of the right must have been voluntary in the sense that it was the product of a free and deliberate choice rather than intimidation, coercion or deception. The record is devoid of any suggestion that police resorted to physical or psychological pressure to elicit the statements. The defendant was not worn down by improper interrogation tactics or lengthy questioning or by trickery or deceit. The officers did not intimidate or threaten respondent in any way. Their questioning was restrained and free from the abuses that so concerned the Court in Miranda.). (Id. at 169-170.)