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Ashcraft v. Tennessee

Supreme Court of the United States · 1944 · Criminal Procedure

Criminal ProcedureConfessionsDue Processcoerced confessionvoluntarinessdue processFourteenth Amendmentinherently coercive

Facts

After Mrs. Ashcraft was found murdered, Tennessee officers investigated for days without uncovering tangible evidence against her husband, Ashcraft. Officers then took Ashcraft into custody and questioned him in a fifth-floor jail room from Saturday evening until Monday morning, about thirty-six hours, while he was held incommunicado and denied sleep and rest, with officers questioning him in relays. The State relied on an alleged confession obtained after this interrogation, and Tennessee conceded in the Supreme Court that the convictions could not stand without the confessions. The state trial court and Tennessee Supreme Court did not affirmatively find the confessions voluntary, and the issue was effectively left to the jury.

Issue

Whether the use of Ashcraft's alleged confession, obtained after approximately thirty-six hours of continuous incommunicado questioning without sleep or rest, violated the Fourteenth Amendment because the confession was compelled rather than voluntary. As to Ware, the question was what disposition should follow once Ashcraft's conviction was reversed on that ground.

Rule

A confession is inadmissible under the Fourteenth Amendment when it is compelled rather than voluntary, and a prolonged secret interrogation that is so inherently coercive as to be irreconcilable with a suspect's mental freedom produces a compelled confession. In reviewing such a claim, the Supreme Court must independently examine the record and is not bound by a jury verdict or by state-court treatment of voluntariness.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Columbus, Ohio, detectives arrested Daniel Rios on suspicion of arson. They kept him alone in a secure interview room for 34 hours, questioned him continuously in relays, denied him any meaningful sleep or rest, and did not allow him to contact anyone outside the station; the prosecution later introduced his written confession at trial.

Daniel argues that admitting the confession violated the Fourteenth Amendment. What is the strongest answer?

Explanation. The majority held that a confession obtained through prolonged secret interrogation by relays of officers, while the suspect is held incommunicado and deprived of sleep or rest, is compelled as a matter of due process because the setting is inherently coercive. Physical brutality is not required. Nor does submitting voluntariness to the jury cure the constitutional problem.