361 U.S. 199 (1960), 50, Blackburn v. Alabama

Docket Nº:No. 50
Citation:361 U.S. 199, 80 S.Ct. 274, 4 L.Ed.2d 242
Party Name:Blackburn v. Alabama
Case Date:January 11, 1960
Court:United States Supreme Court
 
FREE EXCERPT

Page 199

361 U.S. 199 (1960)

80 S.Ct. 274, 4 L.Ed.2d 242

Blackburn

v.

Alabama

No. 50

United States Supreme Court

Jan. 11, 1960

Argued December 10, 1959

CERTIORARI TO THE COURT OF APPEALS OF ALABAMA

Syllabus

After having been discharged from the Armed Forces because of permanent mental disability, and during an unauthorized absence from a Veterans' hospital where he had been classified as 100% "incompetent," petitioner was arrested on a charge of robbery. After eight or nine hours of sustained interrogation in a small room which was at times filled with police officers, he signed a confession written for him by a Deputy Sheriff. Shortly thereafter, he exhibited symptoms of insanity and, after proceedings prescribed by state law, he was found insane and committed to a state mental hospital. Over four years later, he was declared mentally competent to stand trial, and was tried in a state court on the robbery charge. His confession was admitted in evidence over his objection, and he was convicted.

Held: the record clearly establishes that the confession most probably was not the product of any meaningful act of volition, and its use in obtaining petitioner's conviction deprived him of his liberty without due process of law in violation of the Fourteenth Amendment. Pp. 200-211.

(a) Though it is possible that petitioner confessed during a period of complete mental competence, the evidence here establishes the strongest probability that he was insane and incompetent at the time he allegedly confessed. Pp. 207-208.

(b) On the record in this case, there was not such a conflict in the evidence as to require this Court to accept the trial judge's conclusion that the confession was voluntary. Pp. 208-209.

(c) Where the involuntariness of a confession is conclusively demonstrated at any stage of a trial, the defendant is deprived of due process by its use in obtaining his conviction -- even though important evidence concerning the involuntariness of the confession was not introduced until after admission of the confession into evidence and the defendant's counsel did not request reconsideration of that ruling. Pp. 209-211.

40 Ala.App. ___, 109 So.2d 736, reversed.

Page 200

WARREN, J., lead opinion

MR. CHIEF JUSTICE WARREN delivered the opinion of the Court.

Jesse Blackburn was tried in the Circuit Court of Colbert County, Alabama, on a charge of robbery, found guilty, and sentenced to 20 years' imprisonment. By far the most damaging piece of evidence against him was his confession, which he persistently maintained had not been made voluntarily.1 The record seemed to provide substantial support for this contention, and we granted certiorari because of a grave doubt whether the judgment could stand if measured against the mandate of the [80 S.Ct. 277] Fourteenth Amendment to the Constitution of the United States. 359 U.S. 1010. Plenary hearing has hardened this doubt into firm conviction: Jesse Blackburn has been deprived of his liberty without due process of law.

The crime with which Blackburn was charged was the robbery of a mobile store on April 19, 1948. By that date, Blackburn, a 24-year-old Negro, had suffered a lengthy siege of mental illness. He had served in the armed forces during World War II, but had been discharged in 1944 as permanently disabled by a psychosis. He was thereupon placed in an institution and given medical treatment over extended periods until February

Page 201

14, 1948, when he was released from a Veterans Administration hospital for a ten-day leave in the care of his sister. He failed to return to the hospital, and consequently was discharged on May 24, 1948. The robbery of which he stands convicted occurred during this period of unauthorized absence from a mental ward. Blackburn's medical records further disclose that, from 1946, he was classified by the Veterans Administration as 100 percent "incompetent," and that, at the time of his discharge from the hospital, both his diagnosis of "schizophrenic reaction, paranoid type" and his characterization as "incompetent" remained unchanged.

This does not by any means end the record of Blackburn's history of mental illness. He was arrested shortly following the robbery, and, sometime after his confession on May 8, 1948, the Sheriff reported to the circuit judge that Blackburn had exhibited symptoms of insanity. The judge thereupon had Blackburn examined by three physicians, and, after receiving their report, he concluded that there was "reasonable ground to believe that the defendant was insane either at the time of the commission of [the] offense or at the present time." In accordance with the procedure prescribed by Alabama law,2 the judge then directed the Superintendent of the Alabama State Hospitals to convene a lunacy commission. When the commission unanimously declared Blackburn insane, the judge committed him to the Alabama State Hospital for the mentally ill until he should be "restored to his right mind."3 Blackburn escaped from the hospital once, only to be apprehended on another charge, declared insane

Page 202

by a second Alabama circuit judge, and sent back to the hospital. Before his return, he was examined by another set of doctors, who diagnosed his mental condition as "Schizophrenic reaction, paranoid type" and declared that he was "Insane, incompetent, and should be placed in [an] insane hospital." Except for this brief interlude, Blackburn remained in the hospital for over four years, from July, 1948, to October, 1952, at which time he was declared mentally competent to stand trial.

At his trial, Blackburn entered pleas of not guilty and not guilty by reason of insanity. He testified that he could remember nothing about the alleged crime, the circumstances surrounding it, his arrest, his confession, his commitment to the State Hospital, or the early period of his treatment there. He denied the truth of the confession, but admitted that the signature on it appeared to be his. According to a 1944 Army medical report, one aspect of Blackburn's illness was recurrent "complete amnesia concerning his behaviour."

When the prosecutor proposed to introduce Blackburn's confession into evidence, his...

To continue reading

FREE SIGN UP