Beecher v. Alabama
19 L. Ed. 2d 35, 1967 U.S. LEXIS 435, 389 U.S. 35 (1967)
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Rule of Law:
A confession is involuntary and its admission at trial violates the Due Process Clause of the Fourteenth Amendment if it is the product of a continuous stream of coercion, including threats of violence and the exploitation of a defendant's physical and mental vulnerabilities.
Facts:
- On June 15, 1964, the petitioner, a Black convict, escaped from a prison camp in Alabama.
- The next day, a woman's lifeless body was discovered not more than a mile from the camp.
- On June 17, Tennessee police officers captured the petitioner, shooting him in the right leg.
- While the petitioner lay wounded, the local Chief of Police pressed a loaded gun to his face, threatened to kill him if he did not confess, and another officer fired a rifle next to his ear, at which point he immediately confessed.
- Five days later, in an Alabama prison hospital, the petitioner was in intense pain from his leg wound, which would later be amputated, and required morphine injections every four hours.
- Less than an hour after a morphine injection, while feverish and in a 'kind of slumber,' state investigators interrogated him for 90 minutes.
- A medical assistant told the petitioner to 'cooperate' with the investigators.
- During this interrogation, the petitioner signed two detailed written confessions that the investigators had prepared.
Procedural Posture:
- The petitioner was indicted, tried, and convicted of first-degree murder in an Alabama state trial court.
- The trial jury fixed his punishment at death.
- The petitioner's written confessions were admitted into evidence at trial over his objection.
- The Supreme Court of Alabama, the state's highest court, affirmed the conviction.
- The petitioner filed a petition for a writ of certiorari to the Supreme Court of the United States.
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Issue:
Does the admission of confessions violate the Due Process Clause of the Fourteenth Amendment when they are obtained from a wounded and heavily medicated defendant days after he first confessed at gunpoint under threat of death?
Opinions:
Majority - Per Curiam
Yes. The admission of the confessions violates the Due Process Clause of the Fourteenth Amendment because they were involuntary. The uncontradicted facts show an unbroken 'stream of events' from the initial gunpoint confession to the written confessions signed five days later. The petitioner was wounded, threatened with death, still in intense pain, under the influence of morphine, and at the complete mercy of the authorities. A realistic appraisal of these circumstances compels the conclusion that the confessions were the product of gross coercion, and under the Due Process Clause, no conviction tainted by such confessions can stand.
Concurring - Justice Black
Yes. The judgment should be reversed exclusively on the ground that the confession was obtained in violation of the Self-Incrimination Clause of the Fifth Amendment, which applies to the states through the Fourteenth Amendment as established in Malloy v. Hogan.
Concurring - Justice Brennan
Yes. The judgment should be reversed because the confession was inadmissible as involuntary under the standard set forth in Malloy v. Hogan. Under Malloy, the admissibility of a state confession is tested by the Fifth Amendment's command that no person 'shall be compelled in any criminal case to be a witness against himself.' The test is whether the confession was 'free and voluntary,' meaning it must not be extracted by any threats, violence, or improper influence, which was clearly not the case here.
Analysis:
This case reinforces the 'totality of the circumstances' test for confession voluntariness under the Due Process Clause. It establishes that coercion's influence can persist over time, rendering a later confession involuntary if there is no significant 'break in the stream of events' from the initial coercive act. The decision underscores that psychological pressure and the exploitation of a defendant's physical vulnerability (pain, injury, medication) are as constitutionally significant as overt physical violence. The concurrences signal a doctrinal shift toward analyzing such cases under the Fifth Amendment's Self-Incrimination Clause, a trend solidified in later jurisprudence.
