Brief Fact Summary. Petitioner Robert Watts was interrogated for four straight days during the day, and two of the days were spent in solitary confinement. He ended up making incriminating statements resulting in his conviction for murder.
Synopsis of Rule of Law. Use of a confession obtained by relentless police interrogation is a deemed involuntary and thus a violation of the due process clause of the Fourteenth Amendment.
Issue. Is a confession procured after four straight days of interrogation made voluntarily and this valid under the due process clause of the Fourteenth Amendment?
Held. No. Reverse the judgment of the Indiana Supreme Court.
Statements obtained during interrogation do not need to be volunteered to be voluntary and thus valid under the Fourteenth Amendment. However, if a confession is the result of sustained pressure by the police, it is subversive to the accusatorial system and did not arise out of free choice. Here, the pressure was sustained for four days and ran counter to the Due Process’s clause’s function of assuring appropriate procedure without liberty being curtailed.
Concurrence. Justice Hugo Black concurred in the result.
Justice William O. Douglas also concurred, expressing the view that any confession obtained during a period of unlawful detention should not be admissible under the due process clause.
Justice Robert H. Jackson concurred in the result as well.
There comes a point where this Court should not be ignorant as judges of what we know as men.View Full Point of Law