New York Law Review

Tag: Jackson v. Denno

  • People v. Brown, 24 N.Y.2d 168 (1969): Admissibility of Confession in Bench Trials

    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.”

  • People v. Huntley, 15 N.Y.2d 72 (1965): Procedure for Determining Confession Voluntariness After Jackson v. Denno

    People v. Huntley, 15 N.Y.2d 72 (1965)

    In New York, when a defendant challenges the voluntariness of a confession, the trial judge must conduct a hearing outside the presence of the jury to determine voluntariness beyond a reasonable doubt before the confession can be admitted into evidence; this is known as the Massachusetts procedure.

    Summary

    Following the Supreme Court’s decision in Jackson v. Denno, which addressed the procedure for determining the voluntariness of confessions, the New York Court of Appeals in People v. Huntley established the procedure to be followed in New York State. The court adopted the “Massachusetts procedure” requiring the trial judge to determine voluntariness beyond a reasonable doubt in a hearing outside the jury’s presence. The court also outlined procedures for cases already concluded where voluntariness was contested.

    Facts

    Huntley was convicted of robbery in 1960 after a trial where his confession was admitted into evidence. The voluntary nature of the confession was examined during a voir dire and then submitted to the jury as a question of fact. After the Supreme Court’s decision in Jackson v. Denno, Huntley sought reconsideration of his application to appeal to the New York Court of Appeals, which was granted.

    Procedural History

    Huntley was convicted in the Court of General Sessions. His conviction was affirmed by the Appellate Division. He then applied for leave to appeal to the New York Court of Appeals, which was initially denied. After Jackson v. Denno, his application was reconsidered and granted. The New York Court of Appeals then addressed the procedural implications of Jackson v. Denno for New York.

    Issue(s)

    Whether, in light of Jackson v. Denno, New York should adopt a specific procedure for determining the voluntariness of confessions both in ongoing and concluded cases, and if so, what that procedure should be.

    Holding

    Yes, because Jackson v. Denno requires a reliable determination of voluntariness before a confession is presented to the jury. New York adopts the Massachusetts procedure for future cases and provides guidance for previously concluded cases.

    Court’s Reasoning

    The Court of Appeals recognized the necessity of establishing a clear procedure to comply with Jackson v. Denno. The court considered options such as state habeas corpus and coram nobis motions, ultimately deeming a coram nobis motion appropriate for cases where appellate processes have been exhausted. For future trials, the court adopted the “Massachusetts procedure” where “the jury passes on voluntariness only after the judge has fully and independently resolved the issue against the accused” and has made express findings on voluntariness. The court reasoned that this approach aligned with New York’s constitutional mandate for a jury trial on voluntariness issues. The court emphasized that “the Judge must find voluntariness beyond a reasonable doubt before the confession can be submitted to the trial jury. The burden of proof as to voluntariness is on the People.” The court also mandated that the prosecution provide notice to the defense if a confession would be used and allowed the defense to request a preliminary hearing on voluntariness. The Court explicitly stated: “We adopt for New York State the so-called Massachusetts procedure described in the Jackson v. Denno opinion…under which the jury passes on voluntariness only after the judge has fully and independently resolved the issue against the accused.”