Colorado v. Connelly

Summary

The Court, through Chief Justice Rehnquist, held that coercive police activity is necessary to render a confession involuntary under the Fourteenth Amendment and that mental illness alone does not establish constitutional involuntariness. It also held that the State need prove a Miranda waiver only by a preponderance of the evidence and that the waiver's voluntariness depends on the absence of governmental coercion, not freedom from internal psychological compulsion. The Court reversed the Colorado Supreme Court's entire judgment and remanded, leaving other grounds concerning waiver open for reconsideration. Justice Blackmun joined all but the burden-of-proof discussion, which he considered unnecessary and neither raised nor briefed. Justice Stevens agreed that the precustodial statements need not be suppressed but would suppress the custodial statements because Connelly could not voluntarily waive his rights. Justice Brennan, joined by Justice Marshall, dissented, arguing that due process protects free choice independently of police misconduct, that reliability safeguards were necessary, and that the Court's Miranda rulings were both procedurally inappropriate and substantively mistaken.