Miller v. Fenton

Police detective Boyce interviewed Frank Miller (defendant), the prime suspect in a brutal murder. Miller was a 32-year-old with some high school education who had served time before. Boyce assumed a friendly, sympathetic manner and initially falsely told Miller that the victim was still alive. Boyce said he was a brother who just wanted to help Miller unburden his conscience, and that Miller was not a criminal or responsible, just someone who needed help. Throughout the interview, Miller maintained a suspicious, guarded attitude and made remarks that showed that he understood he was in an ordinary police interrogation, not talking with a compassionate friend, and that confession could result in criminal charges and potentially conviction. After about 30 minutes, Miller began making incriminating statements. Miller ultimately confessed an hour into the interrogation then collapsed into an unresponsive state of shock. Police called an ambulance, which took Miller to the hospital, so his confession was never reduced to a written statement. The trial court admitted the tape-recorded confession into evidence and convicted Miller of murder. An intermediate state appellate court reversed, reasoning that the confession was involuntary. The New Jersey Supreme Court disagreed and reinstated the conviction. On federal habeas review, the Third Circuit found the confession admissible, deferring to the trial court's finding. However, the United States Supreme Court reversed, finding that the federal court should have independently reviewed the issue and remanded for redetermination using the correct standard.