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Arizona v. Fulminante, 499 U.S. 279, 111 S.Ct. 1246, 113 L.Ed.2d 302, 59 USLW 4235

Facts

After the murder of his 11-year-old stepdaughter, Fulminante left Arizona and was later incarcerated in a federal prison in New York. There, he befriended Anthony Sarivola, a paid informant for the FBI, who offered protection in exchange for the truth about the murder. Fulminante confessed to Sarivola that he had killed the girl, and this confession was later used against him in his trial for first-degree murder in Arizona. The trial court denied his motion to suppress the confession, leading to his conviction and death sentence.

Fulminante's statements to police concerning Jeneane's disappearance and his relationship with her contained a number of inconsistencies, and he became a suspect in her killing.

Issue

Was Fulminante's confession coerced, and if so, was the admission of that confession at trial a harmless error?

The court also held that the harmless-error rule could not be used to save the conviction.

Rule

The court applied the totality of the circumstances test to determine the voluntariness of a confession, and established that the harmless-error rule applies to the admission of involuntary confessions.

The court applied the appropriate test, totality of the circumstances, cf. Schneckloth v. Bustamonte, 412 U.S. 218, 226, 93 S.Ct. 2041, 2047, 36 L.Ed.2d 854, to determine the confession's voluntariness and plainly found that Fulminante was motivated to confess by a fear of physical violence, absent protection from his friend Sarivola.

Analysis

The court found that Fulminante's confession was coerced due to a credible threat of physical violence from other inmates, which was exploited by Sarivola's offer of protection. The court emphasized that the confession's admission could not be deemed harmless, as it was highly prejudicial and likely influenced the jury's decision. The court noted that the prosecution's case relied heavily on the confession, and without it, the jury might have reached a different conclusion.

The court's finding, permissible on this record, that there was a credible threat of physical violence is sufficient to support a finding of coercion.

Conclusion

The U.S. Supreme Court affirmed the Arizona Supreme Court's ruling that Fulminante's confession was coerced and that its admission at trial was not harmless error, thus ordering a new trial without the confession.

The Arizona Supreme Court held that the confession was coerced, but initially determined that the admission of the confession at trial was harmless error, because of the overwhelming nature of the evidence against Fulminante.

Who won?

Oreste Fulminante prevailed in the case because the court found that his confession was coerced and that its admission at trial violated his constitutional rights.

We affirm the judgment of the Arizona court, although for different reasons than those upon which that court relied.

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Halbert v. Michigan, 545 U.S. 605, 125 S.Ct. 2582, 162 L.Ed.2d 552, 73 USLW 4600, 05 Cal. Daily Op. Serv. 5458, 2005 Daily Journal D.A.R. 7463, 18 Fla. L. Weekly Fed. S 473

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