Mental Illness and Miranda Rights

Facts of the Case

On February 24, 1999, at approximately 11 p.m., the Lynn, Massachusetts, fire department responded to a fire at a three‐family dwelling. Five people were killed in the fire. Charles Loayza's girlfriend Kristina Sutherland and their two children lived in the building. Earlier that day, Mr. Loayza had argued with Ms. Sutherland and threatened to set fire to the building. Two months earlier, Mr. Loayza had set fire to a wreath on the door of his girlfriend's apartment.

The Lynn police went to Mr. Loayza's house and told his mother, Kathleen Hilton, that they were investigating a fire and looking for Mr. Loayza. Hilton told them that her son had become upset that evening after speaking with Ms. Sutherland, with whom he had recently broken up, and had left for work at 7:30 p.m.

Sergeant Cronin requested that Ms. Hilton come to the police station for further questioning about her son. She voluntarily went to the police station where she was interviewed for approximately one‐half hour. Later the next day, police found and arrested Mr. Loayza. He provided an alibi that the police were able to confirm. The police received information that Ms. Hilton had a history of fire‐setting behavior and the investigation shifted focus from Mr. Loayza to Ms. Hilton.

Three days after the fire, on February 27, 1999, Sergeant Cronin returned to Ms. Hilton's apartment and asked her to go to the police station to provide an additional statement. At the station, Cronin gave Ms. Hilton her Miranda warnings. The defendant said that she understood the warnings and signed the appropriate form. Ms. Hilton was not informed that she was a suspect in the arson. The interview proceeded and Ms. Hilton repeated essentially the same facts that she had stated in her earlier interviews. The officers suggested that perhaps she had set the fire. She denied it and added she had no idea who set the fire.

After a brief break, Ms. Hilton was upset. The officers used a sympathetic tone, encouraging her to “just tell them exactly what happened.” The defendant then reported that she was the one responsible for setting the fire.

Two days later, March 1, 1999, the defendant was arraigned in the Lynn division of the district court. The court officer, Susan Marrin, had several responsibilities, including the transportation of detainees between holding cells and the courtroom and reporting criminal activity that she became aware of in and around the courtroom to her supervisor. After the defendant's arraignment, the court officer was escorting Ms. Hilton back to the holding area. On the way, Ms. Hilton said to Ms. Marrin, “I hope he forgives me.” Ms. Marrin said, “Excuse me?” Ms. Hilton answered, “My son, I hope he forgives me. I could have killed my grandchildren.” At that point Ms. Marrin proceeded to ask the defendant questions that elicited a confession to the arson. Ms. Marrin reported this information to a Lynn police officer.

Ruling

The Supreme Judicial Court of Massachusetts found that, based on her mental retardation and mental illness, the lower court had correctly ruled that Ms. Hilton was unable to waive her Miranda rights. The spontaneous statements that Ms. Hilton made to the court officer were not subject to suppression, but Ms. Hilton's responses to questions were properly suppressed.

Discussion

In Miranda v. Arizona, 384 U.S. 436 (1966), the U.S. Supreme Court found that the police, before beginning a custodial interrogation are required to inform suspects of their right to remain silent, their right to counsel, and that anything that they say can be used as evidence against them. These “Miranda rights” may be waived. The waiver, to be valid, must be a knowing, intelligent, and voluntary waiver. The district court subsequently noted that expert testimony described Ms. Hilton as mentally retarded with schizophrenia and schizotypal personality disorder. In Hilton, the court found that the defendant, as a result of her mental illness lacked the capacity to waive her Miranda rights knowingly, intelligently, and voluntarily.

She had been given her Miranda rights before the interrogation became custodial; however, she lacked the capacity to understand her legal rights and the ramifications of the voluntary confession she gave to the police after her interrogation became custodial. The court was also asked to suppress the statements that the defendant, an individual with mental infirmities, spontaneously made to the court officer who was transporting her to the holding area. The issues of voluntariness of a confession given by a mentally ill individual was at the heart of the U.S. Supreme Court's decision in Colorado v. Connelly, 479 U.S. 157 (1986). On August 1983, Mr. Connelly approached a Denver police officer and stated that he had come all the way from Boston to confess a murder. Connelly was taken to police headquarters where he openly detailed his story to the police and subsequently pointed out the exact location of the murder. The next day, Mr. Connelly was sent to a state hospital for an evaluation. He was found to have a psychosis. A psychiatrist opined that the psychosis interfered with his ability to make rational choices and motivated his confession. The trial court suppressed Mr. Connelly's initial statement and custodial confession because they were “involuntary,” notwithstanding the fact that the police had done nothing wrong or coercive in securing the confession.

The U.S. Supreme Court held that coercive police activity is a necessary predicate to finding that a confession is not voluntary within the meaning of the Due Process Clause. The Court, rejecting the assertion that Mr. Connelly's mental condition alone resulted in an “involuntary confession,” found that taking Mr. Connelly's statements and admission into evidence had not deprived him of due process of law. The court noted that although a defendant's mental condition may be a “significant” factor in the voluntariness of a confession, it does not justify a conclusion that his mental condition by itself and absent police coercion or intimidation, results in a statement that should be suppressed.

Consistent with Colorado v. Connelly, the court in Hilton held that, although the court officer was clearly a law enforcement agent for Sixth Amendment purposes, counsel's presence was not required for Ms. Hilton's spontaneous admissions to the officer to be admissible. Answers to questions that followed her spontaneous admission were suppressed.