793 So. 2d 1044 - Edwards v. State’s Empirical Analysis

Citation profile

4 state decisions

Most-quoted passages

The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 5 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “For a confession to be admissible, it must be made voluntarily. Brewer v. State, 386 So.2d 232, 235 (Fla.1980). It may not be obtained by threats, promises, or the exertion of any improper influence. Id. "The constitution does not bar the use . . . of any statements that could be construed as a threat or promise, but only those which constitute outrageous behavior and which in fact induce a confession." Nelson v. State, 688 So.2d 971, 974 (Fla. 4th DCA 1997). Thus, there must be a causal nexus between the improper conduct or questioning and the confession. Id. A confession is not involuntary if officers merely inform a suspect of realistic penalties and encourage or request that person to tell the truth. Id. This is equally true if officers tell the suspect that things would be easier on that person if he or she told the truth. Id. at 973 ; Frazier v. State, 107 So.2d 16, 22 (Fla.1958). An officer's promise to inform prosecutors or the trial court of a suspect's cooperation does not make a confession involuntary. Maqueira v. State, 588 So.2d 221, 223 (Fla.1991); see also Nelson, 688 So.2d at 973 . On the other hand, promises not to prosecute may render a confession invalid. See Interest of K.H., 418 So.2d 1080 (Fla. 4th DCA 1982)(finding confession involuntary where officer promised juvenile he would not be charged, promise was withdrawn, and juvenile, who was "none too bright," assumed confession would revive initial promise).”

   3 later decisions quote this exact passage
   e.g. Chambers v. State · 898 So. 2d 233 - Samuel v. State

2. “Certainly, a threat to charge a suspect with more, and more serious, crimes unless he or she confesses is coercive. Further, it is essentially a promise not to prosecute to the fullest extent allowed by law if that person confesses. Hence, the investigators' threats amounted to an exertion of improper and undue influence, rendering the affected portion of Edwards' statement involuntary.”

   2 later decisions quote this exact passage
   e.g. Chambers v. State · 898 So. 2d 233 - Samuel v. State

3. “At this point, the fire marshal investigator indicated that he did not believe that Edwards was telling the whole truth and threatened to `hit' him with every charge he could hit him with if he was not truthful. Edwards then admitted lighting the fire on the bed to get back at his girlfriend.”

   1 later decision quote this exact passage
   e.g. 898 So. 2d 233 - Samuel v. State