Arizona v. Fulminante
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Arizona v. Fulminante, 499 U.S. 279 (1991), was a decision issued by the United States Supreme Court in 1991 clarifying the standard of review of a criminal defendant's allegedly coerced confession.
In 1982, the 11-year-old stepdaughter of one Oreste Fulminante was murdered in Arizona. Later, Fulminante was incarcerated for an unrelated crime. While in prison, Fulminante met Anthony Sarivola, a fellow inmate, who was also a confidential informant for the Federal Bureau of Investigation. Sarivola offered Fulminante protection from "tough treatment" in prison in exchange for a confession about the murder of Fulminante's stepdaughter. Fulminante agreed, confessing to Sarivola that he murdered his stepdaughter. As a result, Fulminante was charged with the murder, and his confession to Sarivola was used against him at trial.
The trial court denied Fulminante's motion to suppress the confession on the basis that it was coerced because Fulminante might have been subject to violence in prison had he not confessed. Fulminante was convicted and sentenced to death, and appealed to the Arizona Supreme Court, which held that the confession was indeed coerced. Reasoning that a harmless error analysis was inappropriate in the case of involuntary confessions, the court nonetheless ordered a new trial.
In a divided opinion, the United States Supreme Court held that the state supreme court's finding that Fulminante might have been subjected to violence was sufficient to establish a finding of coercion, and therefore affirmed the reversal. In addition, the Court held that a harmless error analysis should nonetheless be applied to any allegedly coerced confession. In either case, the Court held that a new trial was warranted.
