After the defendant’s stepdaughter was murdered in Arizona, he left the state. He was convicted of an unrelated crime and was incarcerated in prison in New York. There, Sarivola, a fellow inmate who was also a paid informant of the government, befriended him. Sarivola told the defendant that he knew the defendant was getting harsh treatment from other inmates because of a rumor he was a child murderer. Sarivola offered him protection in exchange for the truth. The defendant admitted to Sarivola that he had killed his stepdaughter, and he provided details. The defendant made the same confession to Sarivola’s wife. Subsequently, he was indicted for murder.
Whether the defendant’s confession was coerced?
Yes. The confession was the result of mental coercion.
The Court reasoned that the defendant was motivated to confess by a fear of physical violence, absent protection from a government informant. The Court found that a credible threat of physical violence is sufficient to support a finding that the subsequent confession is unreliable.
499 U.S. 279, 111 S. Ct. 1246 (1991)