Miller v. Fenton

796 F.2d 598 (3d Cir. 1986)

Facts:

Miller’s confession was admitted by a New Jersey trial court and he was convicted  of murder.

Issue:

(1) The “voluntariness” of the defendant‘s murder confession. Specifically, whether the tactics of the detective during the  53-minute interrogation were sufficiently manipulative to overbear the will of a person with the [defendant’s]  characteristics.

(2) Whether the detective’s statements were so manipulative or coercive that they deprived  Miller of his ability to make an unconstrained autonomous decision to confess.

Held:

(1) Under the totality of circumstances of this case Miller’s confession was voluntarily given.

Reasoning:

(1) Viewed the limits of permissible interrogation as turning on “a weighing of the circumstances of pressure [applied by the police] against  the power of resistance of the person  confessing.”

(2) No threats and no physical coercion were used.

(3) detective was friendly, repeatedly assured Miller that he was sympathetic to him and wanted to help him unburden his mind.

(4) Psychological ploys may play  a part in the suspect’s decision to confess, but as long as that decision is  a product of the suspect’s own balancing of competing considerations, the confession is voluntary.

Notes:

Looked at education level, age, criminal record, whether Miranda warnings were given, and length of interrogation.

An officer’s lie may affect the voluntariness of the confession but must be analyzed in the context of all the circumstances of the interrogation.

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One comment on “Miller v. Fenton

  1. Pingback: The True Face Of Police

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