Dassey v. Dittman

Dist. Ct. erred in granting defendant’s habeas petition challenging his rape/murder conviction on ground that state trial court improperly admitted his confession, which he claimed was involuntary. While record contained factors that would support finding that confession was involuntary, including fact that defendant was 16 at time of confession, that he had IQ in low 80s, that his confession contained inconsistencies, and that interrogators gave broad assurances that honesty would produce leniency, record also contained factors suggesting that confession was voluntary, including fact that interrogators gave no specific promise of leniency, that defendant spoke freely to interrogators with his mother’s consent after receiving Miranda warnings, that interrogations took place in comfortable settings without physical coercion or intimidation over brief period of time, and that defendant provided many damning details in response to open-ended questions. As such, state-court’s determination that defendant’s confession was voluntary was reasonable, and federal courts cannot declare state-court factual determinations to be unreasonable merely because federal courts would have reached different conclusion. Also, defendant failed to present any case law that condemned specific techniques used by interrogators against defendant. (Dissent opinions filed.)