Colorado v. Connelly

Facts

The Respondent, Francis Connelly (the “Respondent”) approached an off duty police officer and without any provocation told the officer he murdered somebody and wanted to talk about it. The officer advised the Respondent of his Miranda rights. The Respondent said he understood, but wanted to still talk about the murder. The Respondent informed the officer he had been in mental hospitals in the past, but that he was not currently under the influence of any substances. The officer felt that the Respondent understood what he was doing. A detective arrived shortly thereafter and asked the Respondent “what he had on his mind”. The Respondent confessed to the officers that he killed a young girl in Colorado in the past. The Respondent was then taken to the police station and the police learned an unidentified female had been found at about the time the Respondent said he killed the little girl. The Respondent then took the officers to the scene of the crime. At this time, the Respondent did not exhibit any signs of mental illness. The Respondent was held overnight and the next day during an interview with a public defender began exhibiting signs of disorientation. Including, the hearing of voices. He was then sent to a mental hospital, but eventually was deemed competent to proceed at trial. During a preliminary hearing, the Respondent moved to suppress all his statements. A state doctor testified that the Respondent was suffering from chronic schizophrenia and was in a psychotic state the day before he confessed. Specifically, that he was following the voice of god from the time he came to Colorado from Boston to the time he confessed. Based on the doctors testimony, “the Colorado trial court decided that respondent’s statements must be suppressed because they were ‘involuntary.’ [T]he court ruled that a confession is admissible only if it is a product of the defendant’s rational intellect and ‘free will.’ Although the court found that the police had done nothing wrong or coercive in securing respondent’s confession, Connelly’s illness destroyed his volition and compelled him to confess. The trial court also found that Connelly’s mental state vitiated his attempted waiver of the right to counsel and the privilege against compulsory self-incrimination. Accordingly, respondent’s initial statements and his custodial confession were suppressed.” The Colorado Supreme Court affimed and found the “proper test for admissibility is whether the statements are ‘the product of a rational intellect and a free will.’ ”