## Facts

- Francis Barry Connelly approached a Denver police officer and stated that he had murdered someone and wanted to confess.
- Police administered Miranda warnings; Connelly stated he understood his rights and continued speaking.
- Connelly repeated his confession after a detective again provided Miranda warnings, then described the crime in detail and led police to the murder location.
- The next day, while meeting with a public defender, Connelly appeared disoriented and was sent to a state hospital.
- A psychiatrist later testified Connelly had chronic schizophrenia and claimed he confessed in response to “the voice of God,” which affected his ability to make free and rational choices, though he could understand his rights.
- The trial court found no coercive or improper police conduct in obtaining Connelly’s statements.

## Issues

1. Whether the Fourteenth Amendment Due Process Clause requires suppression of a confession as involuntary based solely on the defendant’s mental illness, absent coercive police activity.
2. Whether the State must prove a Miranda waiver by clear and convincing evidence, or only by a preponderance of the evidence.

## Decision

- The Supreme Court reversed the Colorado Supreme Court.
- The Court held that coercive police activity is a necessary predicate for finding a confession involuntary under the Due Process Clause.
- The Court held that the State need prove a Miranda waiver only by a preponderance of the evidence, not by clear and convincing evidence.
- Because Connelly’s confession was not the product of police coercion and he received Miranda warnings he understood, the Federal Constitution did not require suppression of his statements.

## Legal Principles

- A confession is not “involuntary” for Fourteenth Amendment due process purposes without coercive police activity that overbears the suspect’s will.
- A defendant’s mental condition is relevant to evaluating voluntariness but, by itself and apart from official coercion, does not establish a federal due process violation requiring exclusion.
- Exclusion under constitutional confession doctrines is tied to deterring governmental misconduct; absent coercion, suppression is not constitutionally compelled on due process grounds.
- When the State bears the burden to show a valid Miranda waiver at a suppression hearing, it must do so by a preponderance of the evidence.

## Conclusion

The Court limited federal constitutional suppression of confessions by requiring coercive police activity to establish due process involuntariness, and it confirmed that the prosecution’s burden to prove a Miranda waiver is satisfied by a preponderance of the evidence even when the defendant’s mental illness influenced the decision to confess.


Colorado v. Connelly, 479 U.S. 157 (1986)