Brief Amicus Curiae of Professors of Criminal Law, Criminal Procedure, and Constitutional Law in Support of Petitioner
Brandon Garrett
Gregory B. Craig
Donald P. Salzman
Julia K. York
Anne K. Six
SimpleOriginal

Summary

There many issues with the voluntariness of a confession when a juvenile is involved.

2018 | Federal Juristiction

Brief Amicus Curiae of Professors of Criminal Law, Criminal Procedure, and Constitutional Law in Support of Petitioner

Keywords special care; voluntariness analysis; vulnerable persons; psychological coercion; intellectual impairment; juvenile confessions; suggestibility; confession reliability
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Summary of Argument

This Court has long recognized that coerced confessions are antithetical to our accusatorial system. Indeed, this Court’s precedents—rooted in longstanding common law traditions—reflect an abhorrence of confessions coercively wrung from vulnerable suspects. Over the past century, the Court adopted a totality-of-the-circumstances approach to assessing voluntariness of confessions, which examines both the characteristics of the accused and the details of the interrogation. Withrow v. Williams, 507 U.S. 680, 693 (1993); Schneckloth v. Bustamonte, 412 U.S. 218, 226 (1973). In applying this test, “th[e] Court has recognized that coercion can be mental as well as physical, and that the blood of the accused is not the only hallmark of an unconstitutional inquisition.” Blackburn v. Alabama, 361 U.S. 199, 206 (1960). Further, the Court has clearly instructed that the propriety of police techniques must be viewed in terms of their effect on the particular suspect in question. See, e.g., Miller v. Fenton, 474 U.S. 104, 116 (1985). The Court has repeatedly recognized that certain categories of suspects are particularly vulnerable to police coercion, including children, see, e.g., In re Gault, 387 U.S. 1, 45 (1966), and those with intellectual impairments, see, e.g., Fikes v. Alabama, 352 U.S. 191, 196-97 (1957). Indeed, the Court has clearly mandated that “special care” be used in assessing the voluntariness of a juvenile confession. Gallegos v. Colorado, 370 U.S. 49, 53 (1962); see also Gault, 387 U.S. at 45, 55. Careful attention to the impact of the police techniques on the particular suspect effectuates key principles undergirding the Fifth Amendment and Fourteenth Amendment totality-of-the-circumstances test, namely that: (1) psychological coercion can manipulate suspects; (2) juvenile confessions must be reviewed with “special care”; (3) the suspect’s intellectual challenges must be taken into account in a voluntariness review; and (4) when facts are disclosed to suspects, that contamination raises still greater reliability concerns, particularly in confessions involving psychological coercion, juveniles, or those with intellectual challenges. In this case, both the court below and the Wisconsin Court of Appeals made grave doctrinal errors in applying this Court’s longstanding precedent. The circuit court below saw clear evidence of psychological coercion—e.g., the “leading and suggestive” nature of the questioning, the “broad assurances” from police that “honesty would produce leniency,” the “guesses” that petitioner had offered when investigators were not satisfied with his responses, and the nonpublic facts that investigators “blurted out” when they “lost patience,” which petitioner then adopted, Dassey v. Dittmann, 877 F.3d 297, 301, 308, 312 (7th Cir. 2017) (en banc)—but discounted it because “Dassey was not subject to physical coercion.” Id. at 313. That ignores—or, at best, clearly misapplies—the well-established law holding “that coercion can be mental as well as physical.” Blackburn, 361 U.S. at 206; see also Spano v. New York, 360 U.S. 315, 321-24 (1959). In addition, the court below failed to apply “special care” in determining whether the police techniques “as applied to this suspect, are compatible with a system that presumes innocence and assures that a conviction will not be secured by inquisitorial means,” Miller, 474 U.S. at 116, and that asks whether the suspect’s will was in fact overborne. Spano, 360 U.S. at 321-24; see also Lynumn v. Illinois, 372 U.S. 528, 534 (1963). The defendant here was a sixteen-year-old juvenile at the time he confessed. He is borderline intellectually disabled and extremely suggestible. He lacked prior experience with law enforcement and was alone with the police—without parent or lawyer—when making his most inculpatory statements. Merely acknowledging these factors, without paying “close attention to the individual’s state of mind and capacity for effective choice,” Miranda v. Arizona, 384 U.S. 436, 507 (1966) (Harlan, J., dissenting) (citing Gallegos, 370 U.S. 49), simply does not amount to “special care.” Yet, in its voluntariness analysis the court below paid mere lip-service to the import of experienced detectives feeding facts to Brendan Dassey and the impact of those leading and suggestive questions on him. The sections that follow provide a historical overview of this Court’s voluntariness case law, followed by exposition of the errors committed by the court below, and of the divergent approaches taken by other lower courts. In short: This case provides an opportunity for this Court to correct recurring departures from the clearly established voluntariness standard, which forms a bedrock protection against coercive interrogation methods that are anathema to our criminal justice system.

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Summary of Argument

The Supreme Court has consistently recognized that coerced confessions violate the principles of the American justice system. This principle is rooted in common law tradition and is reflected in the Court's precedents. Over the past century, the Court has adopted a totality-of-the-circumstances approach to evaluating the voluntariness of confessions, which considers both the characteristics of the accused and the specific details of the interrogation. This test acknowledges that coercion can manifest mentally as well as physically and the Court has instructed that the effectiveness of police techniques must be analyzed in relation to the particular suspect in question.

The Court has consistently recognized that certain categories of suspects are more vulnerable to police coercion, including children and individuals with intellectual impairments. Therefore, "special care" is required in assessing the voluntariness of a juvenile confession.

The Fifth and Fourteenth Amendments support the totality-of-the-circumstances test. These amendments recognize that: (1) psychological coercion can manipulate suspects; (2) juvenile confessions warrant "special care"; (3) the suspect's intellectual abilities must be considered during a voluntariness review; and (4) the disclosure of nonpublic facts to a suspect raises significant reliability concerns, particularly in confessions involving psychological coercion, juveniles, or those with intellectual challenges.

This case presents an opportunity for the Court to address recurring departures from the established voluntariness standard. By doing so, the Court can reinforce the bedrock protection against coercive interrogation methods that undermine the principles of the American criminal justice system.

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Summary of Argument

The Supreme Court has consistently recognized the importance of protecting individuals from coerced confessions, viewing them as antithetical to the principles of an accusatorial justice system. This principle is rooted in common law traditions and is reflected in the Court's adoption of a totality-of-the-circumstances approach to assess the voluntariness of confessions. This approach examines both the characteristics of the accused and the details of the interrogation, acknowledging that coercion can be mental as well as physical. The Court has emphasized the need for "special care" in assessing the voluntariness of confessions made by juveniles and individuals with intellectual impairments due to their heightened vulnerability to police coercion.

In the present case, the lower courts erred in their application of the Court's voluntariness standard. The court below recognized the presence of psychological coercion, including leading and suggestive questioning, assurances of leniency, and the disclosure of non-public facts by investigators. However, it dismissed these factors because the suspect was not subject to physical coercion. This ignores the well-established legal principle that coercion can be both mental and physical.

Moreover, the court failed to apply "special care" in considering the suspect's age, intellectual disability, and lack of experience with law enforcement. Despite these vulnerabilities, the court merely acknowledged these factors without meaningfully analyzing their impact on the suspect's ability to make a voluntary confession.

This case presents an opportunity for the Supreme Court to reaffirm the importance of the voluntariness standard and to correct the lower courts' departures from this well-established principle. The Court's decision will have significant implications for protecting individuals from coercive interrogation methods and ensuring the integrity of the criminal justice system.

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Summary of Argument

The Supreme Court has consistently recognized that coerced confessions violate the principles of our legal system. The Court has used a "totality of the circumstances" approach to determine if a confession was made voluntarily. This involves considering factors like the suspect's characteristics and the interrogation techniques used.

The Court has acknowledged that certain individuals, like children and those with intellectual disabilities, are more vulnerable to pressure from law enforcement. This means extra care must be taken when evaluating the voluntariness of their confessions.

In this case, the lower courts made mistakes by disregarding the signs of psychological coercion used by investigators. They also failed to apply the “special care” required when evaluating a confession made by a juvenile with intellectual disabilities.

The case highlights the need for the Supreme Court to reassert the importance of the "totality of the circumstances" test and ensure that confessions are not coerced through manipulative interrogation methods.

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Summary of Argument

The Court has said that confessions forced from people are against our justice system. The Court has long looked at how police question people to make sure they are not forced to confess. This is called the "totality of the circumstances" test. The test looks at the person being questioned and how the police talked to them.

The Court said that people who are young or have trouble thinking clearly are especially easy to pressure. So, the Court has said that we have to be extra careful when looking at how police talk to kids or people with learning differences. In this case, the lower court didn't think that the police forced the person to confess because he wasn't physically hurt. But, the Court has said that pressure can be mental, too. The Court should make sure the lower court thought about all the things the Court has said about how police should talk to people.

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Footnotes and Citation

Cite

Brief of Amici Curiae Professors of Criminal Law, Criminal Procedure, and Constitutional Law in Support of Petitioner, Dassey v. Dittmann, No. 17-1172 (U.S. Mar. 26, 2018).

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