Case Citator › Arizona v. Fulminante

Arizona v. Fulminante

Is it still good law? What later courts have actually done to this case.

Limited by some courts
Court
Supreme Court of the United States
Citation
499 U.S. 279
Decided
Confirmed treatments
1
Flagged citations read
184 of 184
Citing cases (total)
5,853
Treatment dates
2012
Limited by some courts
At least one reviewed court has limited this case’s holding to narrower facts or a narrower rule. No reviewed court has overruled it. Arizona v. Fulminante has been limited: all 184 flagged citations have been read, and the confirmed treatment is listed below. The Supreme Court of Illinois held in People v. Wrice that Fulminante did not decide whether harmless-error review applies to a confession produced by police brutality and declined to extend its rule to that context.
More on how this was screened

The other citing opinions applied Fulminante's harmless-error and structural-error framework, placed nearby treatment language on other authorities, or reported Fulminante's own treatment of older precedent.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

5,853 later cases cite Arizona v. Fulminante; 184 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on Arizona v. Fulminante?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Limited

  • The court confined Fulminante's harmless-error rule to confessions not produced by physical police coercion and held that using a physically coerced confession as substantive evidence is never harmless error.

    People v. Wrice · Supreme Court of Illinois · filed

    Hinton, like Zuliani, reinforces our belief that Fulminante did not decide the issue of federal constitutional law squarely before us in the present case. See also United States v. Slater, 971 F.2d 626, 636 (10th Cir. 1992) (citing Fulminante for the proposition that absent “allegations of physical violence on behalf of the police, admission of an involuntary confession is subject to harmless error analysis”); United States v. Jenkins, 938 F.2d 934, 942 (9th Cir. 1991) (“Because the Court was not faced with facts that necessitated its passing on whether harmless-error analysis applies even to brutality-induced confessions, it is unclear whether the Court intended to reach that issue in Fulminante.”). Accordingly, we hold that harmless-error analysis is inapplicable to defendant’s postconviction claim that his confession was the product of physical coercion by police officers at Area 2 headquarters. The per se rule in Wilson, as modified above, stands: use of a defendant’s physically coerced confession as substantive evidence of his guilt is never harmless error.
    Read the full opinion on CourtListener →

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