| Corley v. United States | |
|---|---|
 | |
| Decided April 6, 2009 | |
| Full case name | Corley v. United States |
| Citations | 556U.S.303 (more) |
| Holding | |
| 18 U. S. C. §3501 modified theMcNabb–Mallory doctrine but did not supplant it. | |
| Court membership | |
| |
| Case opinions | |
| Majority | Souter |
| Dissent | Alito, joined by Roberts, Scalia, Thomas |
| Laws applied | |
| 18 U.S.C. § 3501 | |
Corley v. United States,556 U.S. 303 (2009), was aUnited States Supreme Court case in which the court held that 18 U. S. C. §3501 modified theMcNabb–Mallory doctrine but did not supplant it.[1][2]
McNabb v. United States andMallory v. United States generally render inadmissible confessions made during periods of detention that violate the prompt presentment requirement ofFederal Rule of Criminal Procedure 5(a). Rule 5(a), in turn, provides that a "person making an arrest... must take the defendant without unnecessary delay before a magistrate judge...." Congress enacted 18 U. S. C. §3501 in response toMiranda v. Arizona and some applications of theMcNabb–Mallory rule. In an attempt to eliminate Miranda, §3501(a) provides that "a confession... shall be admissible in evidence if it is voluntarily given," and §3501(b) lists several considerations for courts to address in assessing voluntariness. Subsection (c), which focuses onMcNabb–Mallory, provides that "a confession made... by... a defendant... , while... under arrest... , shall not be inadmissible solely because of delay in bringing such person before a magistrate judge... if such confession is found by the trial judge to have been made voluntarily and... within six hours [of arrest]"; it extends that time limit when further delay is "reasonable considering the means of transportation and the distance to... the nearest available [magistrate]."[1]
Johnnie Corley was arrested forassaulting a federal officer at about 8 a.m. Around 11:45,FBI agents took him to aPhiladelphia hospital to treat a minor injury. At 3:30 p.m., he was taken from the hospital to the local FBI office and told that he was a suspect in abank robbery. Though the office was in the same building as the nearest magistrate judges, the agents did not bring him before a magistrate judge, but questioned him, hoping for a confession. At 5:27 p.m., some 9.5 hours after his arrest, Corley began an oral confession that he robbed the bank. He asked for a break at 6:30 and was held overnight. The interrogation resumed the next morning, ending with his signed written confession. He was finally presented to a Magistrate Judge at 1:30 p.m., 29.5 hours after his arrest, and charged with armed bank robbery and related charges.[1]
Thefederal District Court denied hismotion to suppress his confessions under Rule 5(a) andMcNabb–Mallory. It reasoned that the oral confession occurred within §3501(c)'s six-hour window because the time of Corley's medical treatment should be excluded from the delay. It also found the written confession admissible, explaining there was no unreasonable delay under Rule 5(a) because Corley had requested the break. He was convicted of conspiracy and bank robbery.[1]
TheThird Circuit Court of Appeals affirmed. Relying on Circuit precedent to the effect that §3501 abrogatedMcNabb–Mallory and replaced it with a pure voluntariness test, it concluded that if a district court found a confession voluntary after considering the points listed in §3501(b), it would be admissible, even if the presentment delay was unreasonable.[1]
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The Supreme Court issued an opinion on April 6, 2009.[1]
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