Arizona v. Fulminante

Arizona v. Fulminante

Argued October 10, 1990
Decided March 26, 1991
Full case name Arizona v. Fulminante
Citations

499 U.S. 279 (more)

Prior history 161 Ariz. 237, 778 P.2d 602
Holding
The harmless error rule is applicable to the admission of involuntary confessions. Violations of this rule are grounds for granting the defendant a new trial.
Court membership
Chief Justice
William Rehnquist
Case opinions
Majority White (Parts I, II, and IV), joined by Marshall, Blackmun, Stevens, Scalia (Parts I and II only), Kennedy (Parts I and IV only)
Majority Rehnquist (Part II), joined by O'Connor, Scalia, Kennedy, Souter
Concurrence Kennedy (concurring in the court's judgment)
Dissent White (Part III), joined by Marshall, Blackmun, Stevens
Dissent Rehnquist (Parts I and III), joined by O'Connor, Scalia (Part III only), Kennedy and Souter (Part I only)
Laws applied
U.S. Const. amend. V and XIV

Arizona v. Fulminante, 499 U.S. 279 (1991) was a decision issued by the United States Supreme Court clarifying the standard of review of a criminal defendant's allegedly coerced confession.

Facts

In 1982, Jeneane Michelle Hunt, the 11-year-old stepdaughter of Oreste Fulminante was murdered in Arizona. Later, Fulminante was incarcerated for an unrelated crime. While in prison, Fulminante met Anthony Sarivola, a fellow inmate, who was also a confidential informant for the Federal Bureau of Investigation. Sarivola offered Fulminante protection from "tough treatment" in prison in exchange for a confession to the murder of Fulminante's stepdaughter. Fulminante agreed, confessing to Sarivola that he murdered his stepdaughter. As a result, Fulminante was charged with the murder, and his confession to Sarivola was used against him at trial.

The trial court denied Fulminante's motion to suppress the confession on the basis that it was coerced because Fulminante might have been subject to violence in prison had he not confessed. Fulminante was convicted and was sentenced to death. He appealed to the Arizona Supreme Court, which held that the confession was indeed coerced. Reasoning that a harmless error analysis was inappropriate in the case of involuntary confessions, the court ordered a new trial.

Supreme Court decision

In a divided opinion, the United States Supreme Court upheld the state supreme court's conclusion that the threat of violence aimed at Fulminante was credible enough to establish a finding of coercion. The U.S. Supreme Court affirmed the reversal by the Arizona Supreme Court. The U.S. Supreme Court held that a harmless error analysis should be applied to any allegedly coerced confession. In either case, the Court held that a new trial was warranted.

In popular culture

Interpretation of the Fulminante decision is a major plot element in the Law & Order episode Confession.[1]

See also

References

  1. ↑ TV.com Summary of Law & Order "Confession"

Further reading

External links

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