Arizona v. Fulminante (1990)
- Docket
- 89-839
- Decided
- 1990-01-01
Summary
Question: 1. Did the Arizona Supreme Court properly apply the totality of circumstances test when considering whether a suspect's confession to murder was coerced? 2. Did the Arizona Supreme Court properly apply harmless error analysis when considering whether the suspect's coerced confession influenced the trial outcome? Conclusion: Yes and yes. Justice Byron R. White and Chief Justice William H. Rehnquist delivered parts of the opinion, both majorities by a 5-4 vote. The Court held that Fulminante was coerced to confess in violation of the Fifth and Fourteenth Amendments. The Court found that "it was fear of physical violence, absent protection from his friend Sarivola, which motivated Fulminante to confess." This motivation invalidated his confession. Since Fulminante's confession to Donna Sarivola was closely tied to his first coerced confession, the Court dismissed both. The Court also found that the confessions played a determinative role in the trial. It maintained that a "successful prosecution depended on the jury's believing the two confessions." Because the confessions were critical to the outcome of the trial, the fact that they were obtained coercively could not be dismissed as a harmless error. Four justices dissented to using harmless error analysis for coerced confessions on the ground that confessions always significantly affect a trial's outcome.