People v. Brown, 24 N.Y.2d 168 (1969)
The rule in Jackson v. Denno, requiring a separate hearing on the voluntariness of a confession, does not apply to bench trials because judges, unlike juries, can objectively determine voluntariness even after hearing other evidence in the case.
Summary
Brown was convicted of manslaughter in a non-jury trial. He later sought coram nobis relief, arguing his confession was coerced and that Jackson v. Denno entitled him to a post-conviction hearing on voluntariness. The New York Court of Appeals held that Jackson v. Denno, which requires a separate determination of a confession’s voluntariness, does not extend to non-jury trials. The Court reasoned that judges, due to their legal training and experience, are capable of objectively assessing voluntariness even after being exposed to other evidence, unlike juries whom the Supreme Court viewed with distrust.
Facts
On February 20, 1963, Brown was indicted for second-degree manslaughter. Following a non-jury trial, he was convicted and sentenced to 2 1/2 to 5 years in state prison. Brown did not initially appeal. Later, Brown filed for a writ of error coram nobis, claiming a coerced confession was used against him at trial, and that he deserved a “Huntley” hearing under Jackson v. Denno.
Procedural History
The trial court denied Brown’s application without a hearing, stating that Jackson v. Denno does not apply to non-jury trials. The Appellate Division affirmed this decision without opinion. The case then went to the New York Court of Appeals.
Issue(s)
Whether the rule established in Jackson v. Denno, requiring a hearing to determine the voluntariness of a confession, applies when the defendant is tried in a non-jury trial (bench trial) before a judge?
Holding
No, because a judge, unlike a jury, is capable of objectively determining the voluntariness of a confession even after hearing other evidence related to the defendant’s guilt.
Court’s Reasoning
The Court distinguished Jackson v. Denno, emphasizing that the Supreme Court’s concern in that case stemmed from the inability of juries to fairly assess the voluntariness of a confession without being influenced by its content and implications for guilt. The Court of Appeals reasoned that judges, by virtue of their legal training, experience, and judicial discipline, possess the capacity to distinguish between the issue of voluntariness and other evidence bearing on guilt or innocence. The court noted that to extend Jackson v. Denno to bench trials would represent an unwarranted distrust of judges, implying they are incapable of objectivity. The court cited People v. Huntley, noting hearings on voluntariness should be held where possible before the same judge who presided at the trial proper. The court stated: “Errors which loom large to a judge, learned in the law and trained to administer justice in strict accordance with the law, may be scarcely visible to the lay juror.” The court further observed that judges routinely make evidentiary rulings (e.g., on the admissibility of contraband) that require them to disregard inadmissible evidence despite having been exposed to it. The Court concluded, “there is a critical difference between a jury and nonjury trial and, therefore, hold that the rationale of Jackson is inapplicable in the latter situation.”