The Need for ‘Rational Intellect’

Colorado v. Connelly established some mental illness complications or other health factors can render someone unable “to make free and rational choices” and, therefore, unable to be properly advised of Miranda rights. / LAW WEEK FILE

Miranda rights have been the subject of many appeals and cases since 1966. Many cases cite issues with coercion or forced confession resulting from police misconduct, but one landmark Colorado case established that coercion and duress are not the only ways Miranda rights can be considered nullified.

According to court records, Francis Connelly on Aug. 18, 1983, approached an off-duty, uniformed Denver police officer to talk about a murder he said he committed. The officer immediately advised Connelly of his Miranda rights. Connelly reportedly said he understood his rights but still wanted to talk about the murder. 

The officer asked Connelly questions including if he had been drinking or taking any drugs. Connelly denied alcohol and drug use but said he had been a psychiatric patient. The officer again informed Connelly of his Miranda rights, but Connelly responded that it was “all right,” and said his conscience was bothering him enough to confess. The officer later testified that Connelly seemed to fully understand both the situation and his rights.

Sometime later, a homicide detective arrived to speak with Connelly, and the detective again advised Connelly of his Miranda rights. Connelly said “he came all the way from Boston to confess to the murder of Mary Junta, a young girl whom he had killed in Denver sometime during November 1982.”

After Connelly was taken into custody, police found records of an unidentified female body found in April 1983. According to records, Connelly “openly detailed his story to [police], and readily agreed to take the officers to the scene of the killing. Under Connelly’s sole direction, the two officers and respondent proceeded in a police vehicle to the location of the crime.” 

After arriving on the scene, Connelly allegedly pointed out the location of the murder and provided other details of the crime. Police officers later said they “perceived no indication whatsoever that [Connelly] was suffering from any kind of mental illness.”

Connelly was held overnight, and the following morning displayed symptoms of disorientation and confusion, stating in his interview with the public defender’s office that he had been told by “voices” to come to Denver and confess to the crime. Connelly was evaluated at a state hospital for competency and was found incompetent. By March 1984, evaluating doctors deemed Connelly competent to proceed to trial.

At a preliminary hearing, Connelly moved to suppress all of his statements prior to hospitalization. A psychiatrist testified that Connelly had suffered a schizophrenic episode and was in a psychotic state the day before his confession. 

According to Connelly’s psychiatrist, Connelly said he had been following the ‘voice of God,’ who instructed him to withdraw money, buy an airplane ticket and fly to Denver. When Connelly arrived, he said God’s voice became stronger and told him “either to confess to the killing or to commit suicide.” 

The doctor testified Connelly had been experiencing “command hallucinations” that rendered him unable “to make free and rational choices.” He testified that the illness didn’t impair cognitive abilities, so his apparent lucidity was not unusual. While he admitted the “voices” described by Connelly could be a personification of his guilt, he said he believed the confession was motivated by his psychosis.

The trial court agreed, deciding that Connelly’s statements were “involuntary” but found “the police had done nothing wrong or coercive in securing [the] confession.”

The Colorado Supreme Court affirmed the decision to suppress all of Connelly’s incriminating statements.

According to the opinion, “the court found that the very admission of the evidence in a court of law was sufficient state action to implicate the Due Process Clause of the Fourteenth Amendment to the United States Constitution.” 

Colorado v. Connelly was a landmark case on this issue and has been cited more than 4,000 times in similar cases.

– Jess Brovsky-Eaker

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