Issue: Whether an individual diagnosed as paranoid schizophrenic acting in response to "command hallucinations" is competent to waive Miranda rights and his subsequent confession is voluntary and admissible

Index Topics: Competency (to waive rights)

Facts: Connelly, an individual with chronic paranoid schizophrenia, confessed to murder and led police to corroborating evidence. Prior to hearing any details of the confession, police asked Connelly if he had been treated for mental illness and he told police that he had. Police then administered the Miranda warnings and asked Connelly if he understood the warning. He said that he did, waived his right to an attorney, and subsequently gave police enough evidence to bring him to trial. Initially, Connelly was found incompetent to stand trial. After six months of treatment, he was competent to stand trial and attended a preliminary hearing. The psychiatrist who initially evaluated Connelly's competency to stand trial testified that Connelly only confessed because he received command hallucinations that told him to either confess or commit suicide. The trial court then held that the prosecution had failed to show that Connelly's waiver of Miranda was voluntary and ruled the confession and any derivative evidence inadmissible. That decision was appealed to the Colorado Supreme Court. The Colorado Supreme Court held that the initial confession was involuntary, notwithstanding the absence of any police misconduct, because it was the product of command hallucinations that placed Connelly in the dilemma of choosing either to confess or to commit suicide. The court then held that Connelly was not competent to waive the Miranda rights because of his mental illness.

APA's position: APA filed a brief in support of the state arguing that Connelly was not incompetent to waive Miranda and that the confessions were not involuntary simply because he claimed they were the product of command hallucinations. The brief stated that: (1) although the behavioral sciences can provide meaningful assistance to the legal system in evaluating individuals' cognitive capacities, because of fundamental differences between the assumptions underlying the behavioral sciences and the legal system, the behavioral sciences can provide only limited assistance to the legal system in evaluating individuals volitional capacities; (2) from a behavioral science perspective, the available evidence warranted and supported the psychiatric opinion that respondent's cognitive capacity was not impaired; (3) from a behavioral science perspective, the available evidence did not warrant the psychiatric opinion that respondent's volitional capacity was impaired; (4) in the circumstances of this case, suppression of respondent's pre-custodial and post Miranda confessions was not necessary to further the values protected by the Due Process Clause; and (5) clarification of the tests used to determine the admissibility of confessions would facilitate meaningful testimony by psychologists and other behavioral scientists.

Result: The US Supreme Court reversed the Colorado Supreme Court and held that, although the mental condition of the defendant is an important factor in assessing voluntariness, mental condition, by itself and apart from its relation to official coercion cannot make a confession involuntary under the Fourteenth Amendment. To hold otherwise, the Court stated, would be to expand its previous line of voluntariness cases into a far-ranging requirement that courts must divine a defendant's motivation for speaking or acting as he did, despite the lack of any claim that governmental conduct coerced his decision. The Court refused to establish a constitutional right suppressing confessions unless the confession was totally rational and properly motivated. The Court distinguished between excluding confessions based on police coercion and those questioning the reliability of confessions uttered by defendants with severe mental illness. Although there is no constitutional barrier to the admission of uncoerced confessions from psychotic and hallucinatory defendants, the State, based on its own rules of evidence, would have the discretion to refuse to admit those confessions as unreliable. The Court said that decision would be based on state evidentiary, not federal constitutional, law.