Miller v. Fenton
Annotate this Case
474 U.S. 104 (1985)
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U.S. Supreme Court
Miller v. Fenton, 474 U.S. 104 (1985)
Miller v. Fenton
Argued October 16, 1985
Decided December 3, 1985
474 U.S. 104
Petitioner, after a 58-minute interrogation at the New Jersey State Police Barracks, confessed to a murder. The New Jersey trial court rejected his motion to suppress the confession, and the jury found him guilty of first-degree murder. The New Jersey Superior Court Appellate Division reversed, finding as a matter of law that the confession was the result of compulsion, and thus was impermissible under the Fourteenth Amendment's due process guarantee. The New Jersey Supreme Court reversed, finding, after examining the "totality of all the surrounding circumstances," that the interrogation was proper and that the resulting confession, being voluntary, had been properly admitted into evidence. Petitioner then sought a writ of habeas corpus in Federal District Court, which dismissed the petition without an evidentiary hearing. The Court of Appeals affirmed, holding that the voluntariness of a confession is a "factual issue" within the meaning of 28 U.S.C. § 2254(d), which provides that state court findings of fact, with certain exceptions, "shall be presumed to be correct" in a federal habeas corpus proceeding, and that accordingly federal review of the New Jersey Supreme Court's determination that petitioner's confession was voluntary was limited to whether that court applied the proper legal test and whether its factual conclusions were supported by the record. Under this standard, the Court of Appeals concluded that the District Court's denial of the habeas corpus petition was proper.
Held: The voluntariness of a confession is not an issue of fact entitled to the § 2254(d) presumption, but is a legal question meriting independent consideration in a federal habeas corpus proceeding. Pp. 474 U. S. 109-118.
(a) There is no support in this Court's decisions for the suggestion that the enactment of § 2254(d) in 1966 altered this Court's prior confession cases holding that the ultimate issue of "voluntariness" is a legal question requiring independent federal determination. More importantly, § 2254(d)'s history undermines any argument that Congress intended that the ultimate question of the admissibility of a confession be treated as a "factual issue" within the meaning of that provision. Pp. 474 U. S. 109-112.
(b) In addition to considerations of stare decisis and congressional intent, the nature of the "voluntariness" inquiry itself lends support to the
holding in this case. Moreover, the practical considerations that have led this Court to find other issues within the scope of the § 2254(d) presumption are absent in the confession context. Unlike such issues as the impartiality of a juror or competency to stand trial, assessments of credibility and demeanor are not crucial to the proper resolution of the ultimate issue of voluntariness. And the critical events surrounding the taking of a confession almost invariably occur, not in open court, but in a secret and more coercive environment. Pp. 474 U. S. 112-118.
741 F.2d 1466, reversed and remanded.
O'CONNOR, J., delivered the opinion of the Court, in which BURGER, C.J., and BRENNAN, WHITE, MARSHALL, BLACKMUN, POWELL, and STEVENS, JJ., joined. REHNQUIST, J., filed a dissenting opinion, post, p. 474 U. S. 118.