Supreme Court rules delayed voluntary confessions may be suppressed

[JURIST] The US Supreme Court [official website; JURIST news archive] issued two opinions Monday. The Court ruled [opinion, PDF] 5-4 in Corley v. United States [Cornell LII backgrounder; JURIST report] that federal statutory [18 USC § 3501 text] and case [McNabb-Mallory backgrounder] law require suppression of a confession given more than six hours after arrest but before the defendant is presented to a judge if law enforcement authorities unreasonably delay presentment. The US Court of Appeals for the Third Circuit affirmed [opinion, PDF] Corley's convictions for armed bank robbery and conspiracy to commit armed bank robbery, holding that voluntary confessions are admissible, even if there is an unreasonable delay. In an opinion by Justice David Souter, the Court overturned the lower court ruling, holding that in enacting § 3501, Congress intended "to limit, not eliminate, McNabb-Mallory":

We hold that §3501 modified McNabb-Mallory without supplanting it. Under the rule as revised by §3501(c), a district court with a suppression claim must find whether the defendant confessed within six hours of arrest (unless a longer delay was "reasonable considering the means of transportation and the distance to be traveled to the near-est available [magistrate]"). If the confession came within that period, it is admissible, subject to the other Rules of Evidence, so long as it was "made voluntarily and ... the weight to be given [it] is left to the jury." If the confession occurred before presentment and beyond six hours, however, the court must decide whether delaying that long was unreasonable or unnecessary under the McNabb-Mallory cases, and if it was, the confession is to be suppressed.

In this case, the Third Circuit did not apply this rule and in consequence never conclusively determined whether Corley’s oral confession "should be treated as having been made within six hours of arrest," as the District Court held. Nor did the Circuit consider the justifiability of any delay beyond six hours if the oral confession should be treated as given outside the six-hour window; and it did not make this enquiry with respect to Corley’s written confession.
Justice Samuel Alito filed a dissenting opinion, in which Chief Justice John Roberts and Justices Antonin Scalia and Clarence Thomas joined. The ruling resolves a split among the federal circuit courts on how to read § 3501.

The Court ruled [opinion, PDF] unanimously in United States v. Navajo Nation [Cornell LII backgrounder; JURIST report] that the Navajo Nation's claim for money damages against the federal government over amendments to a coal lease fails. The Navajo litigation began in 1993, when the Navajo Nation sued the US government for a violation of the Indian Mineral Leasing Act of 1938 (IMLA) [text], alleging that the Secretary of the Interior breached fiduciary duties to the Nation when he communicated with a mining company with whom the Nation had negotiated a coal mining lease during the mining company's appeal of a Department of the Interior order confirming the terms of the lease. As a result of those communications, the lease between the Navajo Nation and the mining company was renegotiated at terms substantially less favorable to the Nation than the originally approved lease. The case has a complex procedural history, having been argued in both the US Court of Federal Claims and the Court of Appeals for the Federal Circuit twice, as well as the Supreme Court. The Court previously ruled [opinion text] in 2003 that the claim failed, but the case was revived on remand. Writing for the Court, Scalia held: "None of the sources of law cited by the Federal Circuit and relied upon by the Tribe provides any more sound a basis for its breach-of-trust lawsuit against the Federal Government than those we analyzed in Navajo I. This case is at an end." Souter filed a concurring opinion, joined by Justice John Paul Stevens.


 

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