338 U.S. 49 (1949), 610, Watts v. Indiana
|Docket Nº:||No. 610|
|Citation:||338 U.S. 49, 69 S.Ct. 1347, 93 L.Ed. 1801|
|Party Name:||Watts v. Indiana|
|Case Date:||June 27, 1949|
|Court:||United States Supreme Court|
Argued April 25, 1949
CERTIORARI TO THE SUPREME COURT OF INDIANA
Petitioner was arrested on suspicion on a Wednesday and held without arraignment, without the aid of counsel or friends, and without advice as to his constitutional rights until the following Tuesday, when he confessed to murder. Meanwhile, he was held much of the time in solitary confinement in a cell with no place to sit or sleep except on the floor, and was interrogated by relays of police officers, usually until long past midnight. At his trial in a state court, the confession was admitted in evidence over his objection, and he was convicted.
Held: the use at the trial of a confession obtained in this manner violated the Due Process Clause of the Fourteenth Amendment, and the conviction is reversed. Pp. 49-55.
FRANKFURTER, J., lead opinion
MR. JUSTICE FRANKFURTER announced the judgment of the Court and an opinion in which MR. JUSTICE MURPHY and MR. JUSTICE RUTLEDGE join.
Although the Constitution puts protection against crime predominantly in the keeping of the States, the
Fourteenth Amendment severely restricted the States in their administration of criminal justice. Thus, while the State courts have the responsibility for securing the rudimentary requirements of a civilized order, in discharging that responsibility, there hangs over them the reviewing power of this Court.1 Power of such delicacy and import must, of course, be exercised with the greatest forbearance. When, however, appeal is made to it, there is no escape. And so this Court once again must meet the uncongenial duty of testing the validity of a conviction by a State court for a State crime by what is to be found in the Due Process Clause of the Fourteenth Amendment. This case is here because the Supreme Court of Indiana rejected petitioner's claim that confessions elicited from him were procured under circumstances rendering their admission as evidence against him a denial of due process of law.2 226 Ind. 655, 82 N.E.2d 846. The grounds on which our review was sought seemed sufficiently weighty to grant the petition for certiorari. 336 U.S. 917.
On review here of State convictions, all those matters which are usually termed issues of fact are for conclusive determination by the State courts and are not open for reconsideration by this Court. Observance of this restriction
in our review of State courts calls for the utmost scruple. But "issue of fact" is a coat of many colors. It does not cover a conclusion drawn from uncontroverted happenings, when that conclusion incorporates standards of conduct or criteria for judgment which in themselves are decisive of constitutional rights. Such standards and criteria, measured against the requirements drawn from constitutional provisions, and their proper applications, are issues for this Court's adjudication. Hooven & Allison Co. v. Evatt, 324 U.S. 652, 659, and cases cited. Especially in cases arising under the Due Process Clause is it important to distinguish between issues of fact that are here foreclosed and issues which, though cast in the form of determinations of fact, are the very issues to review which this Court sits. See Norris v. Alabama, 294 U.S. 587, 589-590; Marsh v. Alabama, 326 U.S. 501, 510.
In the application of so embracing a constitutional concept as "due process," it would be idle to expect at all times unanimity of views. Nevertheless, in all the cases that have come here during the last decade from the courts of the various States in which it was claimed that the admission of coerced confessions vitiated convictions for murder,3 there has been complete agreement that any
conflict in testimony as to what actually led to a contested confession is not this Court's concern. Such conflict comes here authoritatively resolved by the State's adjudication. Therefore, only those elements of the events and circumstances in which a confession was involved that are unquestioned in the State's version of what happened are relevant to the constitutional issue here. But if force has been applied, this Court does not leave to local determination whether or not the confession was voluntary. There is torture of mind as well as body; the will is as much affected by fear as by force. And there comes a point where this Court should not be ignorant as judges of what we know as men. See Taft, C.J., in the Child Labor Tax Case, 259 U.S. 20, 37.
This brings us to the undisputed circumstances which must determine the issue of due process in this case. Thanks to the forthrightness of counsel for Indiana, these circumstances may be briefly stated.
On November 12, 1947, a Wednesday, petitioner was arrested and held as the suspected perpetrator of an alleged criminal assault earlier in the day. Later the same day, in the vicinity of this occurrence, a woman was found dead under conditions suggesting murder in the course of an attempted criminal assault. Suspicion of murder quickly turned towards petitioner, and the police began to question him. They took him from the county jail to State Police Headquarters, where he was questioned by officers in relays from about eleven thirty that night until sometime between 2:30 and 3 o'clock the following morning. The same procedure of persistent interrogation from about 5:30 in the afternoon until about 3 o'clock the following morning, by a relay of six to eight officers, was pursued on Thursday, the 13th, Friday the 14th, Saturday the 15th, Monday the 17th. Sunday was a day of rest from interrogation. About 3 o'clock on Tuesday morning, November 18, the petitioner made an incriminating statement after continuous
questioning since 6 o'clock of the preceding evening. The statement did not satisfy the prosecutor who had been called in, and he then took petitioner in hand. Petitioner, questioned by an interrogator of twenty years' experience as lawyer, judge and prosecutor, yielded a more incriminating document.
Until his inculpatory statements were secured, the...
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