Supreme Court of the United States · 1952 · Criminal Procedure
due processshocks the consciencepolice conductbodily integrityDue Process ClauseFourteenth Amendmentshocks the consciencesense of justice
Facts
Three Los Angeles County deputy sheriffs, acting on information that Rochin was selling narcotics, entered the dwelling where he lived and forced open the door to his room. They saw two capsules on a night stand; when asked about them, Rochin put the capsules in his mouth. The officers jumped on him and tried unsuccessfully to force the capsules out, then handcuffed him and took him to a hospital, where a doctor, at an officer's direction, forced an emetic solution through a tube into Rochin's stomach against his will. The vomiting produced two capsules containing morphine, and those capsules were the chief evidence used to convict him.
Issue
Whether a state criminal conviction violates the Due Process Clause of the Fourteenth Amendment when the key evidence was obtained by police through unlawful entry, physical struggle, and the forced pumping of the accused's stomach to extract swallowed capsules.
Rule
Under the Due Process Clause, a state may not obtain a conviction by methods that offend those canons of decency and fairness that express the notions of justice of English-speaking peoples. Convictions cannot be brought about by government conduct used to obtain evidence that shocks the conscience or offends a sense of justice.
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10 practice questions + 4 AI-graded essays on this case
One of 10 multiple-choice questions for this case. Pick an answer to see why.
In Tulsa, officers investigating stolen microchips entered Lena Ortiz's apartment without permission after a tip. When they saw Lena swallow a small plastic-wrapped item, two officers pinned her down, failed to pry open her jaw, then took her to a clinic where a physician, at police direction and over Lena's protests, pumped her stomach and recovered the item later used to convict her.
If Lena challenges her conviction under the Fourteenth Amendment, what is the strongest argument?
Explanation. The majority held that due process bars convictions brought about by methods that offend canons of decency and fairness and shock the conscience. Illegal entry, physical struggle, and forced stomach pumping to extract evidence from the body constitute the kind of brutal official conduct the Fourteenth Amendment forbids. The opinion specifically rejected any constitutional distinction between coerced verbal evidence and forcibly extracted physical evidence on these facts.