Summary of Arizona v. Fulminante

Citation: 499 U.S. 279

Relevant Facts: Fulminante was suspected of having murdered his stepdaughter.  He was ultimately arrested in New York for an unrelated crime and consequently incarcerated.  During his prison stint he befriended an individual named Anthony Sarivola, who was an inmate that was paid by the FBI to be an informant on other inmates for the duration of his prison sentence. Fulminante first denied killing his stepdaughter during a conversation with Sarivola, but then admitted to the crime in order to curry favor (protection in prison).  Once released from prison, Fulminante confessed to his friend’s wife.  As a result, charges were filed against Fulminante and he was indicted for murder.  Fulminante argued during the trial’s guilt phase that his confessions could not be used against him because they were coerced.  The Court ruled to include the confessions, which led to his conviction, and the imposition of the death penalty as his sentence.  When the matter was appealed, the Arizona Supreme Court ordered that Fulminante be granted a new trial in which the confessions would no longer be admissible.

Issues: Two main legal questions were presented.  They included the following:

1.  Whether the  Arizona Supreme Court correctly applied the totality of circumstances test when it considered whether a suspect’s confession to murder was coerced?

2. Whether the Arizona Supreme Court correctly applied the harmless error analysis when considering whether the suspect’s coerced confession influenced the trial outcome?

Holding:  The Supreme Court ruled that the Arizona Supreme Court had correctly applied both tests.

Reasoning: The Court reasoned that Fulminante had his rights violated because he had been coerced by his friend who was actually an FBI informant.  Consequently, the Arizona Supreme Court’s ruling for a new trial without the admission of the confessions was correct.  The Court found that “it was fear of physical violence, absent protection from his friend Sarivola, which motivated Fulminante to confess.”  Because Fulminante was motivated by trying to protect his physical safety and even quite possibly his life, his confession was produced under duress.  Since the confessions were significant evidence in the trial, the most appropriate recourse for Fulminante was to order a new trial that did not include submission of his tainted confessions.