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Lynumn v. Illinois

Supreme Court of the United States · 1963 · Criminal Procedure

Criminal ProcedureConfessionsDue Processcoerced confessionvoluntarinessdue processFourteenth Amendmenttotality of circumstances

Facts

After using James Zeno, whom they had arrested on narcotics charges, to "set somebody up," Chicago police had Zeno go to petitioner's apartment and return with a package later determined to be marijuana. When petitioner was arrested, she initially denied selling marijuana to Zeno and said he had merely repaid a loan. She later told officers she had sold it, but testified that she did so only after officers told her she could get 10 years, that state aid for her children would be cut off, and that her young children would be taken away unless she cooperated; the officers largely corroborated that these statements were made. Petitioner had no prior criminal experience, was surrounded in her apartment by three officers and Zeno, and had no friend or adviser present.

Issue

Whether petitioner's oral confession was voluntary under the Due Process Clause of the Fourteenth Amendment when police obtained it by threats concerning imprisonment, loss of custody of her children, and termination of aid unless she cooperated. Also, whether the conviction could stand on state procedural grounds or because any error in admitting the confession was harmless.

Rule

The test is whether the defendant's will was overborne at the time of the confession; if so, the confession is not voluntary and is not the product of a rational intellect and a free will. Admission of a coerced confession over objection violates due process, and the conviction is vitiated even if other evidence might otherwise support guilt.

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

In Cleveland, Ohio, officers arrested Tasha Benton in her apartment on suspicion of selling stolen prescription drugs. During questioning, two officers told her that if she did not admit the sale, her three-year-old son would likely be placed with strangers and her housing subsidy would end, but that if she cooperated they would speak for her and things would "go easier." Tasha had never been arrested before, was alone, and confessed minutes later.

Is Tasha's confession most likely voluntary under the Fourteenth Amendment?

Explanation. The governing question is whether the defendant's will was overborne so that the statement was not the product of a rational intellect and a free will. Threats that a suspect will lose custody of a young child and financial support unless she cooperates, coupled with inducements of leniency, first-time exposure to criminal process, and isolation from advisers, create the kind of impellingly coercive effect that renders a confession involuntary.