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Arizona v. Fulminante

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Significance: The Supreme Court ruled that when an involuntary confession is erroneously admitted in a criminal trial, an appellate court may confirm the conviction if it decides that the defendant would have been found guilty on the strength of the other evidence.


Before the Fulminante decision, if a person was convicted in a trial in which a coerced confession was admitted, the conviction was automatically reversed, regardless of the other evidence used in the trial. When Orestes Fulminante was in prison, a fellow inmate, an informant for the Federal Bureau of Investigation, promised to protect Fulminante from violent prisoners if he would describe the murder of the young girl. At Fulminante's trial for the murder, the prosecution used the account he gave to the informant in combination with other evidence, and Fulminante was found guilty of first-degree murder. The justices agreed that the confession had been coerced and that it should have been excluded from the trial. Disagreeing on almost everything else, the justices issued two rulings. In regard to the central issue, Chief Justice William H. Rehnquist, speaking for a 5-4 majority, held that use of a coerced confession may be excused as a “harmless error” if other evidence is adequate to support a guilty verdict. Rehnquist argued that the Supreme Court had accepted harmless error analysis is regard to other “trial errors” just as detrimental to a defendant. Justice Byron R. White, speaking for a different 5-3 majority, ruled that the impact of Fulminante's confession had not been shown to be harmless beyond a reasonable doubt. This ruling meant that Fulminante was entitled to a new trial in which his confession would not be admitted.