People v. Kulis, 18 N.Y.2d 318 (1966)

A statement obtained from a defendant in violation of their Miranda rights, while inadmissible as direct evidence, can be used to impeach the defendant’s credibility if they testify differently at trial.

Summary

The New York Court of Appeals addressed whether a statement obtained in violation of Miranda could be used to impeach a defendant’s testimony at trial. The majority held that such statements could be used for impeachment purposes. Chief Judge Fuld dissented, arguing that using illegally obtained statements for any purpose undermines constitutional rights and encourages unlawful interrogations. Despite his continued disagreement with the precedent set in *Kulis*, Judge Fuld felt constrained by the majority’s decision to adhere to that ruling and therefore concurred in the affirmance.

Facts

The specific facts of the underlying criminal case are not detailed in Chief Judge Fuld’s concurring opinion. The key fact relevant to the legal principle is that a statement was obtained from the defendant, Kulis, in violation of his Miranda rights.

Procedural History

The case reached the New York Court of Appeals. The court had previously ruled in *People v. Kulis* that statements obtained in violation of Miranda could be used for impeachment. This appeal challenged that precedent. The majority of the court affirmed their previous ruling, while Chief Judge Fuld, who had dissented in the original *Kulis* decision, reluctantly concurred due to the majority’s stance.

Issue(s)

Whether a statement obtained from a defendant in violation of *Miranda v. Arizona* can be used to impeach the defendant’s credibility if they take the stand and testify in their own defense, even though the statement is inadmissible as direct evidence of guilt.

Holding

Yes, because despite concerns about deterring police misconduct and preserving judicial integrity, the court felt bound by its prior decision in *People v. Kulis* which permitted the use of such statements for impeachment purposes.

Court’s Reasoning

Chief Judge Fuld’s concurrence highlights his continued disagreement with the *Kulis* decision. He reiterates his belief that using illegally obtained confessions, even for impeachment, undermines constitutional rights and incentivizes unlawful interrogations. He emphasizes that the imperative of judicial integrity dictates that unlawfully obtained confessions should not be used for any purpose. He notes that numerous other jurisdictions, including several state supreme courts and federal appellate courts, have rejected the *Kulis* rule and deemed illegally procured statements completely unusable. Despite his strong convictions, Judge Fuld acknowledges the majority’s determination to adhere to *People v. Kulis*, and thus feels compelled to concur in the affirmance. He states, “However, in light of the majority’s present determination to adhere to the decision in *People v. Kulis* (18 Y 2d 318, *supra*), I deem myself constrained to cast my vote for an affirmance.” This demonstrates the principle of *stare decisis*, where courts are generally bound to follow established precedent. Judge Fuld’s opinion showcases the tension between personal legal philosophy and the obligation to respect established legal rulings, even when disagreeing with them. This case highlights a split in authority regarding the use of illegally obtained statements, reflecting ongoing debate about balancing law enforcement needs with the protection of individual rights.