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.”