People v. Schompert, 19 N.Y.2d 300 (1967)

A confession obtained from a person under self-induced intoxication is admissible as evidence if it is deemed reliable, considering the confessor’s capacity to understand their statements and the accuracy of the confession as confirmed by subsequent events.

Summary

Schompert appealed his conviction for grand larceny and burglary, arguing his confession was involuntary due to severe alcoholism and intoxication at the time it was made. He voluntarily contacted the police and confessed to the crimes, providing detailed information that led to the recovery of stolen property. The Court of Appeals held that self-induced intoxication does not automatically render a confession inadmissible. The key is the confession’s reliability, which can be assessed by the confessor’s understanding at the time of the statement and whether subsequent events confirm the confession’s accuracy. Because Schompert provided detailed information and the stolen property was recovered as he described, his confession was deemed reliable and therefore admissible.

Facts

Schompert, a chronic alcoholic with a history of psychosis, was in a bar in Rochester and called the police. He told them he had burglarized a premises. The police disbelieved him until he stated he had the stolen goods in a locker at the Greyhound bus station and possessed the key. The police and Schompert went to the locker, and the police found items that had been taken from the burglarized premises.

Procedural History

Schompert was convicted of grand larceny in the second degree and burglary in the third degree in 1963. The Appellate Division affirmed the conviction, and leave to appeal to the Court of Appeals was denied. Schompert then filed a proceeding in the nature of error coram nobis to vacate the judgment of conviction, arguing the involuntariness of his confession. The County Court dismissed his petition after a hearing, and the Appellate Division affirmed the dismissal. Schompert then appealed to the New York Court of Appeals.

Issue(s)

Whether a confession made by a person under the influence of self-induced intoxication is inadmissible as involuntary, regardless of its reliability and corroborating evidence.

Holding

No, because in cases of self-induced intoxication, the key determinant of admissibility is the trustworthiness of the confession, assessed by the confessor’s capacity to understand their statements and whether the confession’s details are confirmed by subsequent events.

Court’s Reasoning

The Court of Appeals distinguished between confessions obtained through coercion or police-induced intoxication (which are inadmissible regardless of truthfulness) and those resulting from self-induced intoxication. In the latter case, the primary concern is the confession’s reliability. The court emphasized that excluding confessions due to coercion or unfairness aims to prevent abuse of power by officials, not to protect wrongdoers from punishment. The court stated: “*proof that the accused was intoxicated at the time he confessed his guilt of crime will not, without more, bar the reception of the confession in evidence. But if it is shown that the accused was intoxicated to the degree of mania, or of being unable to understand the meaning of his statements, then the confession is inadmissible.*”

The court found that although Schompert was highly intoxicated, he provided a detailed and accurate account of the burglary, which was verified by the discovery of the stolen property at the location he specified. This demonstrated that Schompert was sufficiently aware of his actions and the nature of his statements at the time of the confession. The court considered the subsequent confirmation of the confession’s details as strong evidence of its reliability. The Court also noted that it was important and frequently critical whether the intoxication was self-induced or police-induced. The court also notes that Wigmore’s analysis that the fundamental theory upon which confessions become inadmissible is that when made under certain conditions they are untrustworthy as testimonial utterances. Therefore, because the confession was trustworthy, it was admissible.