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Payne v. Arkansas

Supreme Court of the United States · 1958 · Criminal Procedure

Criminal ProcedureCoerced ConfessionsDue ProcessFourteenth Amendmentdue processcoerced confessionvoluntarinessmental coercion

Facts

Petitioner, a 19-year-old Negro with a fifth-grade education and described by the Court as mentally dull, was arrested without a warrant and never taken before a magistrate as Arkansas law required. He was held incommunicado for three days, denied access to family, denied permission to make a telephone call, not advised of any right to remain silent or to counsel, and denied food for long periods. After being questioned repeatedly, including a trip to Little Rock for a lie detector test, the chief of police told him there could be 30 or 40 people outside who wanted to get him and that if he confessed he would try to keep them out and allow him to confess in private. Petitioner then immediately confessed, and that confession was admitted over objection at trial.

Issue

Whether petitioner's confession was coerced within the meaning of the Fourteenth Amendment, so that its admission in evidence over objection denied him due process of law. Also, if the confession was coerced, whether the conviction could stand because there was allegedly sufficient other evidence of guilt.

Rule

The Fourteenth Amendment forbids the use in a state criminal trial of a confession obtained by coercion, whether physical or mental. In deciding whether a confession was coerced, the Court independently examines the record and assesses the totality of the circumstances; if a coerced confession was admitted before the jury and a general verdict was returned, the conviction is vitiated even if other evidence might have supported it.

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

In Mobile, Alabama, police arrested Devin Cole, a 20-year-old warehouse worker, without a warrant and kept him isolated in a city lockup for two days. Officers refused his requests to call his sister, did not bring him before a magistrate, gave him almost no food, and then the police captain told him that angry neighbors were gathering outside and that the officers could keep them away only if he "came clean" right away; Devin confessed immediately.

If Devin's confession is offered at his state murder trial over objection, how should a reviewing court most likely rule?

Explanation. The governing rule is that the Fourteenth Amendment forbids use of a confession obtained by coercion, whether physical or mental. Voluntariness is judged from the totality of the circumstances. Here, isolation, denial of contact, failure to take Devin before a magistrate, lack of food, and especially the statement suggesting danger from an angry crowd that would be averted if he confessed closely indicate mental coercion. Under the majority's reasoning, a confession immediately produced by such fear is not an expression of free choice.