Crane v. Kentucky

476 U.S. 683 (1986)

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Nature of the Case

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Facts

A clerk at a liquor store was shot to death. A week later, police arrested Crane (D) for participation in an unrelated service station holdup. D was 16-years-old. According to police, D began to confess out of the clear blue sky to a host of local crimes including shooting a police officer, robbing a hardware store, and robbing bowling alley. D was transferred to juvenile detention to continue the interrogation. Eventually, D confessed to murder of the clerk. D moved to suppress the confession as a violation of the Fifth and Fourteenth Amendments. D testified that he had been detained in a windowless room for a protracted period of time, had been surrounded by as many as six officers, had repeatedly requested to call his mother and that he had been badgered into making a false confession. The police denied any wrongdoing. At trial, the prosecutor stressed that the case relied almost entirely on D’s confession and on the statement of his uncle who had told police he was present during the holdup and murder. D’s counsel stated that the confessions should not be believed, as they were not consistent with the facts of the crimes. D’s counsel also argued that the surrounding circumstances of the confession were enough to cast doubt on its credibility. The prosecutor then moved in limine to prevent the defense from introducing any testimony bearing on the circumstances of the confession. The prosecutor argued that such evidence bore on the voluntariness of the confession and that matter had already been decided at a suppression hearing. The prosecutor’s motion was granted. The court held that the defense could inquire into the inconsistencies contained in the confession but would not be permitted to develop any evidence about the duration or the circumstances of the event. D continued his objection and made, as was allowed under Kentucky law, what amounts to an offer and showing of proof. D was found guilty and sentenced to 40 years. This appeal resulted under the Sixth and Fourteenth Amendments. Only one dissent was heard at the Kentucky Supreme Court, and the sentence was affirmed; the testimony related solely to voluntariness. The Supreme Court granted certiorari.