Michigan v. Stewart

Brief Filed: 10/22
Court: Michigan Supreme Court
Year of Decision: 2023

Read full-text amicus brief (PDF, 305KB)opens in new window

Whether the Michigan trial court erred in its “determination of the voluntariness of inculpatory statements” by not excluding from evidence a confession that was obtained using tactics known to increase the risk of a false confession.

False Confessions

Joshua Stewart was 18 years old when he was arrested and investigated for a murder and two robberies. Mr. Stewart was arrested when police saw him at the hospital where he took Deontea White, who had been shot. Police believed that Mr. White (aka Prophet) and another man—not Mr. Stewart—committed the robberies and murder and alleged Mr. Stewart was the driver. During the interrogation, which began at 3:40 a.m. and lasted three hours, police lied to him about the evidence they had against him and led him to believe he could receive a two-year sentence in lieu of a 20 years-to-life sentence if he admitted guilt. Stewart confessed and at trial, the jury acquitted him of murder but found him guilty of armed robbery and other offenses. Stewart made a confession to police he was the driver, supplying the only evidence against himself.

The APA’s brief, joined by the Michigan Psychological Association and the National Association of Social Workers, presented the most recent science demonstrating that the psychologically coercive nature of the police-interrogation techniques used in this case would significantly increase the risk of obtaining a false confession.

The Michigan Supreme Court held that circumstances surrounding Stewart’s interrogation created “an environment in which defendant’s free will was overborne,” that the “statements he gave were involuntary,” and thus any use of these statements at trial violated Stewart’s constitutional rights to due process and against self-incrimination. In making its decision, the Court looked at the “totality of the circumstances” surrounding his interrogation, including his age and the timing of his interview, as well as several characteristics of the officers’ behaviors (e.g., references to leniency, their use of falsehoods, and their overall tone and language). The judgment of the Michigan Court of Appeals was reversed and the case was remanded for a new trial. Although APA’s brief was not directly cited in the Court’s decision, the Court did reference “Defendant and amici” several times in its decision, heavily citing the research APA presented on the link between coercive interrogation tactics and false confessions in its brief.