Corley v. United States
2009 U.S. LEXIS 2512, 556 U.S. 303, 129 S. Ct. 1558 (2009)
Rule of Law:
18 U.S.C. § 3501 modified, but did not eliminate, the McNabb-Mallory rule; thus, a voluntary confession made within six hours of arrest is admissible, but a voluntary confession made after six hours of delay and prior to presentment may still be suppressed if the delay was unreasonable or unnecessary under McNabb-Mallory precedent.
Facts:
- On September 17, 2003, federal and state officers arrested Johnnie Corley for assaulting a federal officer around 8:00 a.m. in Pennsylvania.
- Around 11:45 a.m., FBI agents transported Corley to a Philadelphia hospital to treat a minor cut on his hand.
- At 3:30 p.m., agents took Corley from the hospital to the Philadelphia FBI office, located in the same building as the nearest magistrate judges, and informed him he was a suspect in a bank robbery.
- Agents questioned Corley for several hours without bringing him before a magistrate, during which time he signed a form waiving his Miranda rights.
- At 5:27 p.m., approximately 9.5 hours after his arrest, Corley began an oral confession to the bank robbery, continuing until about 6:30 p.m.
- Corley requested a break, so agents held him overnight, and interrogation resumed the next morning.
- Corley signed a written confession on the morning of September 18.
- Corley was finally presented to a magistrate judge at 1:30 p.m. on September 18, 29.5 hours after his arrest.
Procedural Posture:
- Johnnie Corley was charged with armed bank robbery, conspiracy to commit armed bank robbery, and using a firearm in furtherance of a crime of violence in the United States District Court for the Eastern District of Pennsylvania.
- Corley filed a motion to suppress his oral and written confessions under Federal Rule of Criminal Procedure 5(a) and the McNabb-Mallory rule.
- The District Court denied Corley's motion, concluding that the oral confession occurred within §3501(c)'s six-hour window (by excluding time spent receiving medical treatment) and that the written confession was admissible because Corley requested a break from interrogation.
- Corley was convicted by a jury of conspiracy and armed robbery, but acquitted of using a firearm during a crime of violence.
- Corley appealed his conviction to the United States Court of Appeals for the Third Circuit.
- A divided panel of the Third Circuit affirmed the conviction, ruling that it was bound by Circuit precedent holding that §3501 entirely abrogated the McNabb-Mallory rule, replacing it with a pure voluntariness test.
- Corley then filed a petition for a writ of certiorari with the Supreme Court of the United States to resolve a circuit split on the interpretation of §3501.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does 18 U.S.C. § 3501 entirely abrogate the McNabb-Mallory rule, which renders confessions inadmissible if made during periods of unreasonable delay in presentment, or does it merely modify its application by providing a six-hour safe harbor for voluntary confessions?
Opinions:
Majority - David Souter
No, 18 U.S.C. § 3501 did not entirely eliminate the McNabb-Mallory rule but rather modified its application. The Court held that §3501(a) was intended to overrule Miranda, while §3501(c) was intended to qualify McNabb-Mallory, not abrogate it entirely. The Government's interpretation, which argued that §3501(a) makes any voluntary confession admissible, would render §3501(c) nonsensical and superfluous, a reading that violates a basic canon of statutory interpretation, which dictates that statutes should be construed to give effect to all their provisions. The Court emphasized that 'inadmissible' and 'involuntary' are distinct terms, noting that McNabb-Mallory makes even voluntary confessions inadmissible if obtained during an unreasonable delay. Legislative history strongly supports this interpretation, showing that subsections (a) and (b) were aimed at Miranda, while (c) was specifically meant to modify the presentment exclusionary rule, with the six-hour limit being a compromise to prevent indefinite detention. Furthermore, the Government’s position would leave Federal Rule of Criminal Procedure 5(a)'s prompt presentment requirement 'without any teeth,' removing a crucial safeguard against secret interrogation and coerced confessions that dates back to common law. Lastly, Federal Rule of Evidence 402, enacted in 1975, did not abrogate McNabb-Mallory, as its Advisory Committee Notes expressly identified McNabb-Mallory as a surviving, statutorily authorized rule.
Dissenting - Samuel Alito
Yes, Johnnie Corley’s voluntary confession may not be suppressed under the McNabb-Mallory rule because 18 U.S.C. § 3501(a) directly and unequivocally states that a confession 'shall be admissible in evidence if it is voluntarily given.' Justice Alito argued that the plain and unambiguous language of §3501(a) should be applied according to its terms. While acknowledging that this reading might make §3501(c) appear superfluous, he contended that the antisuperfluousness canon is not an absolute rule and Congress sometimes enacts redundant provisions. He suggested that §3501(c) could be interpreted to apply to 'otherwise voluntary' confessions, meaning a confession is admissible if given within six hours of arrest and if no other factor besides pre-presentment delay makes it involuntary. The dissent found the specific-vs.-general statute canon inapplicable, as there is no direct conflict between (a) and (c), only a 'negative implication' drawn from (c). It was also argued that the prompt presentment requirement of Rule 5(a)(1) can be enforced through other means without excluding voluntary confessions, especially given that Miranda warnings now provide similar protections against coercion at an earlier stage. The dissent stated that while legislative history shows §3501(a) was meant to target Miranda, it also aimed to reinstate the general voluntariness rule, and the reach of a statute can be broader than its specific legislative targets. Finally, the dissent asserted that a literal reading of §3501(a) does not override other standard rules of evidence (like privilege or hearsay), as the phrase 'admissible if voluntarily given' has always been understood in conjunction with other evidentiary rules.
Analysis:
This decision represents a significant clarification of the interplay between a federal statute aimed at confession admissibility and a judicially created exclusionary rule, resolving a long-standing circuit split. It reinforces the enduring importance of the McNabb-Mallory rule as a procedural safeguard against coercive police tactics and secret detention, even in the post-Miranda era, by affirming judicial oversight of prompt presentment. The ruling underscores the Court's commitment to statutory interpretation principles, particularly the avoidance of superfluity and adherence to legislative history, even when a statute's literal language might suggest a different outcome. For law enforcement, it means confessions obtained after six hours of pre-presentment delay remain vulnerable to suppression, compelling officers to adhere to the prompt presentment requirement or be able to justify any such delay as reasonable under the narrow exceptions.
