The case involved Johnnie Corley. He was arrested for assaulting a federal officer, but his confession was delayed for his first court appearance (Oyez, n.d.). He did not confess being part of a robbery until six hours of his arrest lapsed. He only appeared before the magistrate the next day. Corley is sentenced due to armed bank robbery, use of a firearm and carrying a gun in the continuance of violent crimes. Corley was arrested for being a suspect of robbing a credit union in Norristown.
The Federal police filed the case. Corley was found to be guilty of the offence by the District Court. He was charged with conspiracy to armed robbery under United States Code section 371, use and possession of a firearm under section 924 c and armed robbery violation under section 2113 d (Bennigson & Harivandi, 2009). Moving to the Third Circuit, his guiltiness was asserted. The Circuit court had mixed suppositions regarding what extent section 3501 annulled Mallory. Consequently, he appealed this decision to the Supreme Court.
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The matter with the case was the decision of the Court on confessions. Notably, the federal agents who apprehended him did not take him to court for his preliminary appearance (Findlaw, n.d.). It took 29hours thirty minutes, whereby they obtained a confession from him. The federal law and preceding court decisions dictated that valid admissions for the trial have to be collected within six hours of arrest. The matter of contention, in this case, was what courts should do with confessions in situations a delay happens before the first appearance in Court. Corley argued his claim on the bases of delayed disclosure. He referred to section 3501 c of the United States Code that stated admissibility of confession should be made within six hours of arrest. The issue was due to the ambiguous interpretation of the words voluntariness and inadmissibility (Bennigson & Harivandi, 2009. Therefore he argued that these words should be given independent significance when making an interpretation. He further contends that justifying delay past six hours is unworkable if the delay was not owed to suppression. The government argues that section 3501 overrules Mallory because it does not permit barring of voluntary confessions as it states when confessions should be admitted. Therefore delay is not the only basis of exclusion within the six-hour timeframe as section 3501 a makes voluntary disclosures acceptable (Oyez, n.d.). The government identifies that Congress established an exclusionary rule disallowing the use of unlawfully obtained evidence as part of the Public Law thus if they meant to have excluded the evidence due to delay they would have done so in section 3105. The government argues that subsection makes inadmissible and involuntary synonyms.
The Supreme Court had to take appropriate measures on the case. It ordered lower courts to scrutinize if Corley’s statement was conducted within six hours of arrest. The Court advised that the confession had to be rejected if found that the delay was unreasonable (Oyez, n.d.). Justice Stephen Breyer, Anthony Kennedy, John Paul Stevens, Souter and Ruth Bader Ginsburg agreed to this. Other Judges had a different opinion. These were Samuel Alito, John Roberts, Antonin Scalia and Clarence Thomas who argued that confessions are voluntary therefore should be considered as evidence regardless of the time given before the prisoner is taken to Court for the first time. This was per the statement by the 18 United States Code that any criminal suit brought by the United States; a confession that is given voluntarily should be used as evidence thus Corley’s confession was viable. In contrary Justice Souter was guided by the 18 United States Code section 3501 that outlined confessions made during detention and violated swift presentment as per the Federal Rules of Criminal Procedure linger inadmissibility even when voluntarily given.
The fifth amendment of the United States Constitution safeguards criminal defendants. It protects them from testifying against themselves; therefore confessions given to the police and investigators can only be used in trials if they are made voluntarily without coercion of the defendants (Bennigson & Harivandi, 2009). So federal prosecutions are directed by the Federal Rules of Criminal Procedure. When a person is arrested, full investigations and trial begin after they are brought in front of a magistrate and informed of the rights. It consequently determines if there is adequate footing for the arrest. It should be done without superfluous delay. The Court’s rule on Mallory prohibits trial judges from acknowledging evidence confessions obtained during a needless delay. Therefore the defendant is shielded from providing pre-presentment confessions to the police interrogation or consequence to being in their custody. As Corley argues, Mallory endures past the six-hour timeline. The government asserts that section 3501 overrules Mallory by declaring voluntariness as the sole possible foundation for suppressing confessions. Additionally, it makes undue delay sheer consideration in determining the voluntariness of confessions obtained after six hours of arrest.
This case between Corley and the United States awards the Supreme Court a sensitive query on statutory interpretation. This could have a weighty impact on the admissibility of statements made by defendants after they are arrested except before presentment to a judge. As Corley argues that statutes ought to be read to permit the suppressing of confessions made after six hours of apprehension even after finding they were involuntary obtained (Bennigson & Harivandi, 2009. Justices Alito dissents this and proposes the confession should be valid regardless of the time obtained. In the United States rule, confessions should not be suppressed unless discovered to have been received involuntary. Otherwise delay in presentment is just one of the aspects in determination. Therefore justice should be based on voluntary admissions.
Reference
Bennigson, C., & Harivandi, Z. (2009). Corley v. United States (07-10441). Retrieved from https://www.law.cornell.edu/supct/cert/07-10441
Findlaw. FindLaw's United States Supreme Court case and opinions. Retrieved from https://caselaw.findlaw.com/us-supreme-court/556/303.html
Oyez. Corley v. United States. Retrieved from https://www.oyez.org/cases/2008/07-10441
