Yes, his confession was forced and totally unfair. To decide this, you have to look at everything that happened. Given that Culombe wasn't very smart, was held for days, couldn't get a lawyer, and had his family used against him, his will was clearly broken. The confession wasn't his free choice, so it can't be used against him.

Yes, the confession was forced. Some judges agreed with the final decision but for simpler reasons. One said the facts obviously show he was coerced. Another group of judges said the most important mistake was when the police ignored his request for a lawyer. They believe once a suspect asks for a lawyer, the police have to stop questioning them.

No, his confession was not forced. These judges thought that Culombe simply decided on his own to tell the truth. They didn't think the police did anything bad enough to call the confession forced, so they believed his conviction should have been upheld.

Yes, the confession was forced out of him. The police kept him for a long time and asked him many questions, which was too much for someone who didn't fully understand his rights or how to get a lawyer. Because of this, the confession can't be used in court. The State must find evidence on its own and not rely on forcing confessions. When someone is no longer making choices for themselves because of pressure, that confession is not valid.

I don't think it was wrong for the State to decide that Culombe's 'Wednesday' confessions were his own choice to try to improve his situation by admitting things, and not because of improper actions by the police. Culombe's extra confession on Saturday night seems very natural and goes against what the Court is saying. I think the Connecticut courts used the right standards in deciding Culombe's confessions were voluntary.

I agree with some parts of the main opinion but disagree with other parts in general. However, I would rather not give my views on many of the hard questions talked about unless the facts of a specific case make it necessary. I don't see a reason to make an exception here, so I can't join the main opinion. Instead, I join Justice Brennan's separate opinion.

This case is based on the idea that anyone accused of a crime has the right to talk to a lawyer before speaking with the police. If they ask for a lawyer and are refused, they are denied the 'help of a lawyer for their defense' that the Constitution promises. Culombe can't read well and has mental problems. He didn't see a lawyer until six days after being arrested and after he confessed to the police. Not letting him have a lawyer when he asked for one violated his constitutional rights.

The facts in Part V of Justice Frankfurter's opinion show that all of Culombe's confessions, not just the Wednesday ones, were forced out of him. Based on our past cases, none of them can be used as evidence against him.

If it is not, if his will has been overborne and his capacity for self-determination critically impaired, the use of his confession offends due process.

A confession is voluntary if it is " `the product of an essentially free and unconstrained choice by its maker.'"

The essence of this basic constitutional principle is "the requirement that the State which proposes to convict and punish an individual produce the evidence against him by the independent labor of its officers, not by the simple, cruel expedient of forcing it from his own lips."

"The line of distinction is that at which governing self-direction is lost and compulsion, of whatever nature or however infused, propels or helps to propel the confession."

"Despite modern advances in the technology of crime detection, offenses frequently occur about which things cannot be made to speak. And where there cannot be found innocent human witnesses to such offenses, nothing remains—if police investigation is not to be balked before it has fairly begun—but to seek out possibly guilty witnesses and ask them questions …

Indeed, the Court noted the exonerations of mentally retarded people who had "unwittingly confessed to crimes they did not commit." Id.

After consideration of the time defendant had been in custody—five and a half hours, a much shorter period than was involved in the cited cases—and the circumstances of the custody, reviewed in note 2, it still remains true, as in Crooker, that: "On this record we are unable to say that petitioner's confession was anything other than voluntary."

"Each of these factors, in company with all of the surrounding circumstances—the duration and conditions of detention (if the confessor has been detained), the manifest attitude of the police toward him, his physical and mental state, the diverse pressures which sap or sustain his powers of resistance and self-control—is relevant." Id

Yes. The use of Culombe's confessions violates the Due Process Clause because they were obtained involuntarily. The ultimate test for the admissibility of a confession is voluntariness, which must be determined by examining the totality of the circumstances. No single factor is decisive, but the combination of Culombe's prolonged detention, his mental deficiency and illiteracy, the manifest police determination to secure a confession, the frustration of his request for counsel, the use of a sham arraignment to prolong custody, and the calculated emotional pressure applied through his wife and daughter critically impaired his capacity for self-determination. These coercive forces overbore his will, making his confession an instrument of compulsion, not of free choice, and its admission into evidence was unconstitutional.

Yes. While concurring in the judgment to reverse the conviction, this opinion does not join Justice Frankfurter's opinion because it is an overly broad and abstract 'treatise' on coerced confessions that goes beyond what is necessary to decide the specific facts of the case. The better judicial practice is to decide cases on the narrowest possible grounds. Therefore, this opinion joins Justice Brennan's more fact-specific concurrence.

Yes. The conviction must be reversed because the police denied Culombe's request for counsel. Any confession obtained after an accused's request for a lawyer is refused violates the Sixth and Fourteenth Amendments' guarantee of the Assistance of Counsel. This denial of a fundamental right is, by itself, sufficient to render the subsequent confession inadmissible, without needing to resort to a 'totality of the circumstances' analysis. The system of secret police interrogation falls heaviest on the poor, weak, and illiterate, and only a broad guarantee of counsel can ensure equal justice.

Yes. The conviction must be reversed because all of Culombe's confessions were coerced. A straightforward application of the Court's precedents, such as Fikes v. Alabama, to the undisputed facts of this case is sufficient to demonstrate that the confessions were involuntary and therefore inadmissible. It is not necessary to limit the holding to only the 'Wednesday' confessions; the coercive atmosphere tainted all subsequent statements.

No. The use of the confessions did not violate the Due Process Clause. Despite Culombe's subnormal mentality, the state courts could have constitutionally concluded that his confessions were the product of a deliberate and voluntary choice to 'make a clean breast of things,' rather than the result of improper police coercion. The record lacks the usual hallmarks of coercion, and a later, spontaneous confession he made on Saturday night further supports the conclusion that his statements were voluntary. The judgment of the Connecticut courts should be affirmed.

Yes, the defendant's confession was coerced and therefore inadmissible. The police interrogation methods and the defendant's prolonged custody, combined with his mental deficiency and lack of legal assistance, overbore his will and critically impaired his capacity for self-determination. The use of his confession offends due process. The essence of this constitutional principle is the requirement that the State produce evidence against an individual by the independent labor of its officers, not by the cruel expedient of forcing it from the defendant's own lips. The line of distinction is at which governing self-direction is lost and compulsion propels the confession.

I am unable to consider that it was constitutionally impermissible for the State to conclude that petitioner's 'Wednesday' confessions were the product of a deliberate choice on his part to try to ameliorate his fate by making a clean breast of things, and not the consequence of improper police activity. Petitioner's supplemental confession on the following Saturday night, which as depicted by the record bears all the indicia of spontaneity, is especially persuasive against this Court's contrary view. I find no constitutional infirmity in the standards used by the Connecticut courts in evaluating the voluntariness of petitioner's confessions.

I agree with some portions of the majority opinion and disagree with other portions on an abstract level. However, I would prefer not to write on many of the difficult questions discussed until the facts of a particular case make such writing necessary. I see no reason for making an exception in this case, and I am therefore unable to join the opinion which announces the judgment of the Court. Accordingly, I join the separate concurring opinion of Justice Brennan.

This case is controlled by the principle that any accused has the right to consult a lawyer before talking with the police; and if he makes the request for a lawyer and it is refused, he is denied 'the Assistance of Counsel for his defence' guaranteed by the Sixth and Fourteenth Amendments. Petitioner is illiterate and mentally defective. He did not see an attorney until six days after he was first arrested and after he had confessed to the police. The denial of petitioner's request that he be given the right of counsel was a violation of his constitutional rights.

The facts stated in Part V of the opinion of Justice Frankfurter require the conclusion that all and not alone the Wednesday confessions were coerced from the petitioner, and that under our cases none is admissible in evidence against him.

Culombe v. Connecticut

Case Podcast

Rule of Law:

The Legal Principle

Facts:

Procedural Posture:

How It Got Here

Issue:

Legal Question at Stake

Opinions:

Majority, Concurrences & Dissents

Analysis:

Why This Case Matters

Gunnerbot