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Keywords

defendantliabilitytrialtestimonymotioninterrogationcredibility
defendanthearingtrialtestimonymotioncredibility

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Crane v. Kentucky, 476 U.S. 683, 106 S.Ct. 2142, 90 L.Ed.2d 636, 54 USLW 4598, 20 Fed. R. Evid. Serv. 801

Facts

Prior to his murder trial, the defendant moved to suppress his confession, arguing it was coerced. The trial court found the confession voluntary and denied the motion. At trial, the defendant sought to introduce testimony about the interrogation's circumstances to challenge the confession's credibility, but the court ruled this testimony inadmissible, leading to a conviction based primarily on the confession.

Prior to his trial for murder in a Kentucky court, petitioner moved to suppress his confession. Following a hearing, the trial court determined that the confession was voluntary and denied the motion.

Issue

Did the exclusion of testimony regarding the circumstances of the defendant's confession violate his rights under the Sixth and Fourteenth Amendments?

The question presented is whether this ruling deprived petitioner of his rights under the Sixth and Fourteenth Amendments to the Federal Constitution.

Rule

The court held that evidence about the circumstances surrounding a confession is relevant not only to its voluntariness but also to its credibility, which is a matter for the jury to assess.

The holding below rests on the apparent assumption that evidence bearing on the voluntariness of a confession and evidence bearing on its credibility fall in conceptually distinct and mutually exclusive categories.

Analysis

The U.S. Supreme Court found that the Kentucky Supreme Court's reasoning, which treated evidence of voluntariness and credibility as mutually exclusive, was flawed. The Court emphasized that the circumstances of a confession can significantly impact its credibility and that the defendant must be allowed to present evidence that could cast doubt on the confession's reliability.

The U.S. Supreme Court found that the Kentucky Supreme Court's reasoning, which treated evidence of voluntariness and credibility as mutually exclusive, was flawed.

Conclusion

The U.S. Supreme Court reversed the Kentucky Supreme Court's decision, ruling that the exclusion of the testimony deprived the defendant of a fair trial and remanded the case for further proceedings.

690 S.W.2d 753, reversed and remanded.

Who won?

The defendant prevailed because the U.S. Supreme Court determined that his constitutional rights were violated by the exclusion of critical evidence regarding the confession.

The U.S. Supreme Court reversed the Kentucky Supreme Court's decision, ruling that the exclusion of the testimony deprived the defendant of a fair trial.

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