## Facts

- Donald M. Miller was convicted in New Jersey state court of murdering his former girlfriend.
- After his arrest, a state detective conducted an extended interview during which Miller confessed.
- Miller moved to suppress the confession, alleging it was involuntary under the Fourteenth Amendment Due Process Clause due to psychological pressure and coercive interrogation tactics.
- The trial court denied suppression, found the confession voluntary, admitted it at trial, and Miller was convicted; state appellate courts affirmed.
- Miller sought federal habeas relief under 28 U.S.C. § 2254, again challenging voluntariness; the federal district court independently reviewed the record and denied relief.
- The Third Circuit treated voluntariness as a legal (or mixed) question, independently reviewed the record, found the confession involuntary, and ordered habeas relief.
- The Supreme Court granted certiorari to determine whether voluntariness is a factual finding entitled to § 2254(d) deference or a legal/mixed question requiring independent federal judgment.

## Issues

1. Whether the due process “voluntariness” of a confession, when challenged on federal habeas review, is a question of fact governed by 28 U.S.C. § 2254(d)’s presumption of correctness.
2. Whether voluntariness is instead a legal or mixed question requiring independent federal determination, while deferring to state findings on subsidiary historical facts.

## Decision

- The Supreme Court reversed the Third Circuit and remanded.
- The Court held that the ultimate determination of confession voluntariness under the Due Process Clause is a legal or mixed question subject to independent federal judgment on habeas review.
- The Court also held that subsidiary historical facts found by the state courts (e.g., what occurred during interrogation and credibility-related findings) remain entitled to § 2254(d)’s presumption of correctness, absent a statutory exception.
- The Court did not finally decide whether Miller’s confession was voluntary; it directed further proceedings applying the correct division between deference on historical facts and independent review of the ultimate constitutional question.

## Legal Principles

- Confession voluntariness under the Fourteenth Amendment depends on the totality of the circumstances, including both the accused’s characteristics and the interrogation’s details, and asks whether the statement was the product of rational intellect and free will.
- Under 28 U.S.C. § 2254(d), state-court findings of basic, primary, or historical facts are presumed correct on federal habeas review unless an exception applies.
- The ultimate constitutional characterization—whether established facts amount to an involuntary confession—is an “ultimate” legal or mixed question requiring independent federal determination.
- Federal habeas courts must separate (a) what happened (historical facts) from (b) whether those facts satisfy the constitutional standard (voluntariness).

## Conclusion

The Court clarified that, in federal habeas proceedings, state courts receive deference for historical fact-finding about the interrogation, but federal courts must independently decide the ultimate due process question whether a confession was voluntary under the totality of the circumstances.


Miller v. Fenton, 474 U.S. 104 (1985)