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07-10441 CORLEY V. UNITED STATES DECISION BELOW: 500 F.3d 210 CERT. GRANTED 10/1/2008 QUESTION PRESENTED: Whether 18 U.S.C. § 3501 — read together with Fed. R. Crim. P. Rule 5(a), McNabb v. United States, 318 U.S. 332 (1943), and Mallory v. United States, 354 U.S. 449 (1957) — requires that a confession taken more than six hours after arrest and before presentment be suppressed if there was unreasonable or unnecessary delay in bringing the defendant before the magistrate judge. Several United States Courts of Appeals have addressed this issue and have issued conflicting decisions, and the panel in this case was split two to one on the issue. This Court granted certiorari to consider the issue in United States v. Alvarez-Sanchez, 511 U.S. 350 (1994), but then resolved the case on a separate “threshold” ground and expressly left open “the subtle questions of statutory construction concerning the safe harbor set out in § 3501(c).” Id. at 356. LOWER COURT CASE NUMBER: 04-4716
In the case of Johnnie Corley v. United States, the Supreme Court ruled on whether a confession obtained after an unreasonable delay in bringing a suspect before a judge could be admitted as evidence if it was given voluntarily and without coercion. The court held that under federal law (18 U.S.C § 3501), confessions made within six hours of arrest can be used at trial unless they were involuntarily given. However, for confessions made after this period, judges must consider factors such as delay length and reasons to determine their admissibility. In Corley's case, he confessed to bank robbery nearly 29 hours after his arrest but argued that his confession should not have been allowed into evidence because he wasn't promptly presented before a magistrate judge. The Supreme Court agreed with him by applying the McNabb-Mallory rule which excludes voluntary confessions elicited during lengthy detention prior to arraignment.
In the dissenting opinion for the case of Johnnie Corley v. United States, Justice Alito argued that the majority's interpretation of 18 U.S.C §3501 was incorrect and inconsistent with Congress' intent when it enacted this statute. He believed that Congress intended to overrule Miranda v. Arizona in its entirety, not just partially as suggested by the majority. According to him, if a confession is voluntary under traditional due process standards then it should be admissible regardless of whether or not there was compliance with Miranda warnings or delay in presentment before a magistrate judge. Furthermore, he criticized the majority’s reliance on legislative history arguing that such an approach can lead to arbitrary results and judicial policy-making rather than faithful interpretation of statutory text.