Mental Sanity and Confessions: The Supreme Court's New Version of the Old "Voluntariness" Standard

Although the voluntariness standard has not been entirely superseded by Miranda v. Arizona because it is applicable to confessions obtained through police coercion, in spite of compliance with Miranda's technical requirements, it has receded into relative obscurity in the wake of Miranda. In Colorado v. Connelly, however, the United States Supreme Court confronted a novel case which neatly juxtaposed questions relevant to the voluntariness test with issues arising from Miranda's dictates. This article will examine the issues raised in Connelly, critique the Court's application of both the voluntariness standard and Miranda to the facts of Connelly, and suggest alternatives to the Supreme Court's interpretation and application of both the voluntariness doctrine and Miranda to the unique factual pattern presented by Connelly. In addition, the implications of Connelly at the state level will be assessed.