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Jackson v. Denno

Supreme Court of the United States · 1964 · Criminal Procedure

Criminal ProcedureConfessionsDue ProcessVoluntariness Hearingsinvoluntary confessiondue processFourteenth Amendmentvoluntariness

Facts

After being shot during an encounter with a police officer, Jackson was questioned at a hospital and made incriminating statements both shortly after arrival and again immediately after receiving demerol and scopolamine. At trial, evidence conflicted about his physical and mental condition during interrogation and about whether his statements were the product of coercion or impairment. Under New York practice, the trial judge did not make an independent final determination of voluntariness when the evidence presented a fair question; instead, the confession was admitted and the jury was instructed to decide voluntariness along with guilt. The jury convicted Jackson of first-degree murder.

Issue

Whether the New York procedure that submitted the voluntariness of a confession to the same jury deciding guilt, without a separate and reliable determination by another tribunal, satisfied due process under the Fourteenth Amendment. Also, what remedy was required once that procedure was found unconstitutional.

Rule

A defendant has a constitutional right at some stage of the proceedings to object to the use of a confession and to receive a fair hearing and a reliable determination of voluntariness, uninfluenced by the truth or falsity of the confession. Due process is not satisfied by a procedure that allows the convicting jury alone to determine voluntariness under a general verdict when the record does not clearly show a separate, reliable resolution of the coercion issue and disputed facts underlying it.

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

In Phoenix, prosecutors introduced Omar Vega's signed confession at his murder trial after Omar testified that detectives threatened to keep him awake for two more days unless he signed. The trial judge ruled only that the evidence raised a factual dispute, admitted the confession, and instructed the same jury deciding guilt to determine whether the confession was voluntary and to disregard it if involuntary. The jury returned a general guilty verdict.

Did the procedure satisfy due process?

Explanation. Due process requires that a defendant have a fair hearing and a reliable determination of voluntariness, uninfluenced by the truth or falsity of the confession. A procedure is unconstitutional when the same jury deciding guilt alone resolves voluntariness and returns only a general verdict, because the record does not show a clear, separate, reliable resolution of the coercion issue or its underlying disputed facts.