Colorado v. Connelly

In formulating the majority opinion, the justices acknowledged that the lower courts were correct in their assumption that the specter of involuntary confession was an important factor in considering the validity of an admission of guilt. Toward that end, coercion by police played a significant role. However, while Connelly's mental incapacity may have also been another "significant factor" with respect to "voluntariness," the justices could find no cause to consider such circumstance as a valid rationale to consider whether due process according to Miranda was a matter for consideration. In authoring the majority opinion, Justice Rehnquist postulated that "only if we were to establish a brand new constitutional right--the right of a criminal defendant to confess to his crime only when totally rational and properly motivated--could respondent's present claim be sustained." Just because police took the petitioner's statements and just because the state's prosecutor chose to submit those statements into evidence did not constitute a violation of the Due Process Clause of the Fourteenth Amendment.

While Colorado was required to prove the appropriateness of their evidence under a motion to suppress (according to Lego v. Twomey [1972]), the state was only obligated to validate their action through a preponderance of evidence to be granted waiver. Because circumstantial evidence in Connelly's trial overwhelmingly supported the state's case, his confessions, too, were admissible. Thus, the Colorado Supreme Court did not apply a standard of "clear and convincing evidence" in rendering a decision. Moreover, while Connelly's confession might be characterized, according to the petitioner's claim, as coercion from "the voice of God," it was in no way appropriate to consider Connelly's assertion that such a "command" or motivation, however hallucinatory, comprised a challenge to his constitutional right to due process under the Fourteenth Amendment. As such, the U.S. Supreme Court moved to reverse the decision of the Colorado Supreme Court and remand the case back for further adjudication.