Blackburn v. Alabama
361 U.S. 199 (1960)
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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, based on the totality of the circumstances, there is a strong probability the defendant was insane and incompetent at the time of the confession, rendering it not the product of a rational intellect and a free will.
Facts:
- Jesse Blackburn, a 24-year-old, suffered from a lengthy history of mental illness, including a psychosis diagnosis from his military service, and was classified by the Veterans Administration as 100% 'incompetent'.
- On February 14, 1948, Blackburn was released from a VA hospital on a ten-day leave but failed to return.
- The robbery he was charged with occurred on April 19, 1948, while he was on an unauthorized absence from the mental ward.
- Blackburn was arrested, and on May 8, 1948, he was interrogated by police officers for eight to nine hours in a small, confined room.
- A Chief Deputy Sheriff composed a narrative confession based on Blackburn's answers, which Blackburn signed two days later.
- Shortly after the confession, a lunacy commission was convened, which unanimously declared Blackburn insane at the time of the robbery and at the time of his subsequent admission to a state hospital.
Procedural Posture:
- Jesse Blackburn was tried for robbery in the Circuit Court of Colbert County, Alabama.
- The trial judge admitted Blackburn's confession into evidence over the defense's objection.
- A jury convicted Blackburn, and he was sentenced to 20 years' imprisonment.
- Blackburn appealed to the Alabama Court of Appeals, an intermediate appellate court, which affirmed the conviction.
- The Alabama Supreme Court, the state's highest court, denied his petition for certiorari.
- The U.S. Supreme Court granted certiorari, vacated the judgment, and remanded the case back to the Alabama Court of Appeals.
- The Alabama Court of Appeals reaffirmed the conviction, and the Alabama Supreme Court again denied certiorari.
- The U.S. Supreme Court granted certiorari a second time to hear the case.
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Issue:
Does the use of a confession at trial violate the Due Process Clause of the Fourteenth Amendment when the defendant has a documented history of severe mental illness and the confession was obtained after a prolonged interrogation while he was without counsel or family?
Opinions:
Majority - Mr. Chief Justice Warren
Yes. The use of Blackburn's confession violated the Due Process Clause of the Fourteenth Amendment because the evidence establishes the strongest probability that he was insane and incompetent at the time he confessed. The court must consider the 'totality of the circumstances,' and a confession must be the product of a rational intellect and a free will to be voluntary. Here, Blackburn's extensive history of diagnosed psychosis and incompetency, combined with a prolonged eight- to nine-hour interrogation in a tiny room without friends, family, or counsel, renders the confession involuntary. The testimony of a police officer that Blackburn 'talked sensible' is insufficient to overcome the compelling medical evidence of insanity. A conviction based on a statement made while insane offends a basic sense of justice and is a clear denial of due process.
Analysis:
This case significantly solidifies the principle that a defendant's mental state is a critical factor in the 'totality of the circumstances' test for determining the voluntariness of a confession. It establishes that a confession procured from a demonstrably insane or mentally incompetent individual is inherently involuntary and its use violates due process. The decision reinforces the Supreme Court's role in independently reviewing the factual record to protect constitutional rights, and it sets a high bar for the state to overcome compelling evidence of a defendant's mental incompetence when seeking to admit a confession.
