Miller v. Fenton
474 U.S. 104 (1985)
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Rule of Law:
In a federal habeas corpus proceeding, the ultimate question of the voluntariness of a defendant's confession is a legal question requiring independent federal review, not a factual finding entitled to a presumption of correctness under 28 U.S.C. § 2254(d).
Facts:
- On August 13, 1973, 17-year-old Deborah Margolin was found murdered in a rural New Jersey area.
- Based on a general description from the victim's brothers, police tentatively identified Frank Miller and found him at his job.
- Miller agreed to go to the police barracks for questioning, where he was informed of his Miranda rights and signed a written waiver.
- During a 58-minute interrogation, Detective Charles Boyce repeatedly lied to Miller, falsely claiming the victim was still alive and could identify him, that bloodstains were found on Miller's stoop, and that Miller had been identified at the scene.
- Detective Boyce acted sympathetically, suggesting the perpetrator had a 'mental problem' and needed medical help rather than punishment, and offered to help Miller get psychiatric assistance.
- After these techniques, Miller confessed to the murder.
- Immediately following his confession, Miller went into a 'state of shock' and was so unresponsive that an ambulance was called to transport him to the hospital.
Procedural Posture:
- The New Jersey trial court denied Miller's motion to suppress his confession, and a jury found him guilty of first-degree murder.
- Miller (appellant) appealed to the New Jersey Superior Court, Appellate Division, which reversed the conviction, finding the confession was the product of 'intense and mind bending psychological compulsion.'
- The State of New Jersey (appellant) appealed to the Supreme Court of New Jersey, which reversed the appellate court and reinstated the conviction, holding the confession was voluntary.
- Miller filed a petition for a writ of habeas corpus in the U.S. District Court for the District of New Jersey, which dismissed his application.
- Miller (appellant) appealed to the U.S. Court of Appeals for the Third Circuit, which affirmed the dismissal, holding that the state court's voluntariness finding was a factual issue entitled to a presumption of correctness under 28 U.S.C. § 2254(d).
- The U.S. Supreme Court granted certiorari to resolve a conflict among the circuit courts on the issue.
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Issue:
Is a state court's determination that a confession was voluntary a 'factual issue' entitled to a presumption of correctness in a federal habeas corpus proceeding under 28 U.S.C. § 2254(d)?
Opinions:
Majority - Justice O'Connor
No. The ultimate issue of a confession's voluntariness is a legal question requiring independent federal determination, not a factual finding entitled to the § 2254(d) presumption of correctness. An unbroken line of precedent establishes that federal courts have a duty to make an independent evaluation of the record to determine whether a confession comports with the Due Process Clause. The legislative history of § 2254(d) indicates Congress intended to codify the standards from Townsend v. Sain, which treated voluntariness as a mixed question of law and fact subject to plenary federal review. The voluntariness inquiry has a unique legal dimension, assessing whether police interrogation techniques are compatible with a constitutional system that presumes innocence. While subsidiary factual questions (e.g., what the police said or did) are presumed correct, the ultimate constitutional conclusion based on the totality of those facts is a matter for independent federal review.
Dissenting - Justice Rehnquist
Yes. The determination that a confession was voluntary is not sensibly distinguishable from other determinations that the Court has held are factual issues entitled to the § 2254(d) presumption, such as juror impartiality or competency to stand trial. The majority's reliance on stare decisis is misplaced, as most of the precedents it cites involved direct review, not federal habeas corpus. Recent Court decisions have taken a more reasoned approach to § 2254(d), and this ruling is a step backward. Furthermore, the Court of Appeals indicated it would have reached the same conclusion even with independent review, so remanding the case only causes unnecessary litigation and delay for a crime that occurred 12 years ago.
Analysis:
This case clarifies the standard of review for confession voluntariness in federal habeas cases, firmly establishing it as a matter of law subject to de novo review. The decision draws a crucial distinction between 'subsidiary historical facts,' which receive deference, and the 'ultimate constitutional question,' which does not. This reinforces the role of federal courts as the final arbiters of federal constitutional rights, ensuring that state-court conclusions on this critical due process issue are not insulated from meaningful federal oversight. The ruling prevents the § 2254(d) presumption of correctness from eroding the federal judiciary's power to protect individuals from coerced confessions.
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