Colorado v. Connelly

In his dissent, Justice Stevens agreed that simply recording the confession of a suspect who might be mentally incapacitated or even admitting that confession into evidence did not necessarily mean that a confession was involuntary. Neither did such action necessarily constitute noncompliance with the Due Process Clause. However, Stevens believed that a defendant's incompetence to stand trial certainly rendered him incompetent to reasonably waive his Miranda rights as well. Similarly, Justices Brennan and Marshall believed a defendant's mental state was a reasonable consideration when determining the validity of a waiver of Miranda rights. In their opinion, the confession of a mentally ill person was one that was not given of his own volition. As such, the state could not reasonably offer proof that the defendant freely waived his Miranda rights. The justices pointed out that without Connelly's confession, police had not collected evidence which would have led to a sufficiently valid case to charge him with murder. Thus, due process required the independent collection of physical evidence which would, of its own weight, substantially contribute to the merits of the case. Absence of police misconduct, then, required that the evidence gathered had to be the by-product of a free, voluntary confession. As such, all minority justices agreed, the lower courts were correct in their decision to suppress the petitioner's statements made to police because he was unable to make an intelligent decision at the time of his confession.