Crane v. Kentucky
476 U.S. 683 (1986)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
Evidence regarding the circumstances under which a confession was obtained is admissible at trial for the purpose of challenging the confession's credibility, regardless of a pretrial judicial determination that the confession was voluntary.
Facts:
- On August 7, 1981, a liquor store clerk in Louisville, Kentucky, was shot and killed during a robbery.
- A week later, police arrested the petitioner, a 16-year-old named Crane, for an unrelated robbery.
- While in custody, Crane began confessing to numerous local crimes and was transferred to a juvenile detention center for further interrogation.
- After initially denying involvement, Crane confessed to the liquor store murder.
- Crane's confession contained several inconsistencies with the known facts of the crime, such as the time of day it occurred and whether money was stolen.
- Crane later alleged that he was held for a protracted period in a small, windowless room, surrounded by as many as six officers, was denied permission to call his mother, and was badgered into giving a false confession.
Procedural Posture:
- Petitioner Crane filed a pretrial motion in Kentucky state trial court to suppress his confession, arguing it was coerced.
- The trial judge conducted a hearing and denied the motion, finding the confession was voluntary.
- At trial, the prosecutor filed a motion in limine to prevent the defense from introducing testimony about the circumstances of the confession.
- The trial judge granted the prosecutor's motion, ruling the evidence pertained only to the issue of voluntariness, which had already been decided.
- A jury found Crane guilty of murder, and he was sentenced to 40 years in prison.
- Crane (appellant) appealed to the Kentucky Supreme Court, which affirmed the conviction, holding the excluded testimony was properly barred because it related solely to voluntariness.
- Crane petitioned the U.S. Supreme Court for a writ of certiorari, which was granted.
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 a trial court's exclusion of testimony regarding the physical and psychological circumstances of a defendant's confession, on the grounds that it relates only to the already-decided issue of voluntariness, deprive the defendant of their Sixth and Fourteenth Amendment right to a meaningful opportunity to present a complete defense?
Opinions:
Majority - Justice O'Connor
Yes. The exclusion of testimony about the circumstances of a confession deprives a defendant of their constitutional right to present a complete defense. The Kentucky Supreme Court erred by assuming that evidence bearing on voluntariness and evidence bearing on credibility are mutually exclusive categories. While a trial judge determines the legal question of a confession's voluntariness, the jury is tasked with the factual question of its reliability and credibility. Precedent like Jackson v. Denno and Lego v. Twomey establishes that a defendant must be free to familiarize the jury with the circumstances surrounding a confession. Stripping the defendant of the ability to describe the physical and psychological environment that yielded the confession makes it impossible to answer the critical question: 'If the defendant is innocent, why did he previously admit his guilt?' Without a valid state justification for excluding such central, exculpatory evidence, the defendant is denied the 'meaningful opportunity to present a complete defense' guaranteed by the Constitution.
Analysis:
This decision clarifies the critical distinction between the judge's legal determination of a confession's voluntariness and the jury's factual determination of its credibility. It solidifies the principle that a state procedural rule cannot be used to bar a defendant from presenting relevant evidence that is central to their defense, especially when a confession is the primary evidence of guilt. The ruling ensures that juries are not presented with a confession in a vacuum but are instead given the full context needed to properly weigh its truthfulness, thereby reinforcing a defendant's Sixth and Fourteenth Amendment rights.
Unlock the full brief for Crane v. Kentucky