Colorado v. Connelly

Six months later, doctors who had evaluated and treated the defendant decided that he was ready to attend his trial. When he appeared at a preliminary hearing, before Colorado State Court, Connelly moved to suppress all of his prior statements. The defendant said that, at the time, he was hearing the "voice of God" and that was what made him confess to murder. Called to testify on the defendant's behalf, Dr. Metzner explained that Connelly was in a stage of chronic schizophrenia at least one day prior to his confession. The "command hallucinations" Connelly experienced interfered with his ability to make independent and rational choices. He further explained that the psychosis Connelly was experiencing could motivate him to confess, and that "voices" he was hearing at the time could be interpreted as the defendant's feeling of guilt. However, while opining that Connelly's psychosis motivated him to confess, Metzner also allowed that even in that state, Connelly's cognitive abilities were not affected and his mental state did not interfere with his ability to understand his rights as they were presented by the police.

The Colorado trial court ruled that the petitioner's confessions should be suppressed because they were not voluntary. Citing Townsend v. Sain (1963) and Culombe v. Connecticut (1961), the court held that confessions were admissible only when the defendant was capable of exercising "rational intellect and free will." While the police did not coerce a confession, Connelly was in a state wherein his mental illness incapacitated him temporarily and rendered invalid his waiver of Miranda rights, especially his right to counsel and the right against self-incrimination. Accordingly, his confession was suppressed at trial.

On appeal the Colorado Supreme Court agreed that rationality and free will were absent since Connelly was mentally ill at the time of his confession. The court further pointed out that police coercion was not the only criteria for characterizing a confession as involuntary. Mental illness was, itself, a way that "free choice may be overborne." Thus, when the state's prosecutor moved to admit his confession during trial, the Due Process Clause of the Fourteenth Amendment was applicable. As such, because Connelly was unable "to make a valid waiver" of his rights, due process was violated and, the Colorado Supreme Court ruled, the lower court was correct in excluding Connelly's statements.

The U.S. Supreme Court granted certiorari because the conclusions of the lower court seemed at odds with previous rulings by the Court. Believing that the rules of evidence sufficiently addressed the matter of confessions by a suspect who may have been mentally incompetent, the justices did not consider previous decisions regarding coerced confessions or Miranda rights violations. Those rulings were inapplicable. As such, the U.S. Supreme Court reversed the decisions of the lower courts.