Commonwealth v. Knapp
27 Mass. 477 (1830)
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Rule of Law:
If a defendant makes a confession under a promise of immunity from the government on the condition that they testify against their accomplices, that confession is admissible as evidence against the defendant in their own trial if they subsequently refuse to fulfill the condition by testifying.
Facts:
- Joseph J. Knapp was arrested as an accomplice in a murder.
- Reverend Henry Colman visited Knapp in jail and offered to seek government protection for him in exchange for a disclosure.
- Hoping to become a state's witness, Knapp made initial verbal disclosures to Colman.
- Colman then obtained a written letter from the Attorney-General promising Knapp he would not be prosecuted for the offense.
- The promise was conditioned on Knapp making a full, explicit disclosure and testifying truthfully against his accomplices.
- After receiving this written pledge, Knapp made a detailed confession which was written down and signed by him on every page.
- Subsequently, at the trial of his accomplice, J. Francis Knapp, Joseph J. Knapp refused to testify.
Procedural Posture:
- The defendant, Joseph J. Knapp, was indicted as an accessory to murder and brought to trial before the Supreme Judicial Court of Massachusetts.
- During the trial, the prosecution offered the defendant's written confession into evidence.
- The defendant's counsel objected to the admission of the confession, arguing that it was not voluntary as it had been procured by a promise of favor.
- The court held a hearing on the admissibility of the confession, which included testimony from Reverend Henry Colman regarding the circumstances under which the confession was obtained.
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Issue:
Is a written confession, made by a defendant after receiving a formal promise of immunity from the prosecution conditioned on his full and truthful testimony against accomplices, admissible as evidence against him at his own trial if he later breaches that agreement by refusing to testify?
Opinions:
Majority - Putnam J.
Yes. A written confession made under a promise of immunity is admissible if the defendant fails to uphold their end of the agreement. While a confession induced by a mere hope of favor is inadmissible, the circumstances change once that hope is realized through a formal government promise. At the point Knapp made his written confession, the initial improper influence had been removed; he was no longer acting under a mere hope but was in possession of a concrete offer from the government. He was free to accept its terms or reject them. By accepting the offer and confessing, he entered into an agreement. His subsequent refusal to testify constituted a breach of that agreement, which absolved the government from its promise of immunity and rendered his confession, made as part of that agreement, admissible against him. The court adopts the English common law rule that an accomplice who is admitted as a 'king's witness' but then refuses to testify can be convicted upon his own confession.
Analysis:
This case establishes a critical exception to the rule excluding confessions induced by promises of leniency. It solidifies the legal framework for cooperation agreements, clarifying that they are conditional contracts where a defendant's failure to perform (testify) relieves the government of its obligation (immunity). This precedent provides prosecutors with a powerful tool, as it prevents defendants from strategically confessing to gain an advantage and then reneging on their promise to testify, thereby ensuring that such agreements are not easily manipulated. The decision affirms that a defendant who breaches a cooperation agreement forfeits the protections it afforded, including the suppression of their confession.
