Culombe v. Connecticut

In December 1956, two men were shot and killed at Kurp’s Gasoline Station (Kurp’s) in New Britain, Connecticut, following a string of similar holdups and murders in the area. In February 1957, law-enforcement officers began to suspect that Arthur Culombe (defendant) and Joseph Taborsky had been involved in some of the holdups. Culombe was a 33-year-old man with an IQ of 64 and a mental age of approximately nine years. On February 23, officers took Culombe and Taborsky to the state-police headquarters and questioned them repeatedly about the holdups. Over the next several days, officers detained Culombe and Taborsky and engaged in conduct admittedly designed to obtain confessions, including questioning the men at the police station and during car rides, taking Culombe to Kurp’s, using Culombe’s wife to try and get Culombe to confess, and bringing unnecessary breach-of-peace charges against the men that subjected them to an intimidating courtroom proceeding. The officers never advised Culombe about his constitutional rights and did not honor Culombe’s request for a lawyer. Culombe ultimately made five oral confessions and signed three typed confessions admitting his involvement in the Kurp’s killings. Taborsky also confessed to the Kurp’s killings. The State of Connecticut (plaintiff) indicted Culombe and Taborsky and tried them jointly for first-degree murder. During trial, the court allowed the jury to hear some of Culombe’s and Taborsky’s confessions, overruling the men’s objections that the confessions were improperly obtained in violation of the Fourteenth Amendment. The jury convicted Culombe and Taborsky, and the state court affirmed their convictions. Culombe petitioned the United States Supreme Court for a writ of certiorari, and the Court issued the writ.