Corley v. United States

Summary

The Supreme Court held that 18 U.S.C. § 3501 narrowed but did not abolish the McNabb-Mallory rule excluding confessions obtained after unreasonable delay in presentment: subsection (a) was aimed at overruling Miranda, while subsection (c) shelters only confessions made within six hours of arrest, leaving later pre-presentment confessions subject to suppression if the delay was unnecessary or unreasonable. Reading subsection (a) to admit every voluntary confession would render subsection (c) superfluous, and the statute's legislative history confirmed the narrower intent. The Court also rejected the Government's fallback argument that Federal Rule of Evidence 402 superseded McNabb-Mallory, noting the Advisory Committee Notes expressly identified the rule as surviving. It vacated the Third Circuit's judgment and remanded for application of the six-hour framework to Corley's oral and written confessions. Justice Alito, dissenting, would have read § 3501(a)'s plain text to render every voluntary confession admissible regardless of presentment delay.