Haynes v. Washington
373 U.S. 503 (1963)
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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 was obtained through police coercion that overbears the suspect's will, such as through threats of continued incommunicado detention and promises of outside contact conditioned upon confessing.
Facts:
- On December 19, 1957, Raymond L. Haynes was arrested by Spokane police approximately 30 minutes after a gasoline service station robbery.
- Upon arriving at the station, police booked Haynes for 'investigation' on the 'small book,' a status which prevented him from making phone calls or having visitors.
- Though Haynes made two oral admissions of guilt shortly after his arrest, he was held for approximately 16 hours.
- During this 16-hour period, Haynes repeatedly asked police for permission to call his wife and an attorney.
- Police officers consistently refused his requests, telling him he would be allowed to make a call only after he 'cooperated' and provided a signed, written confession.
- The morning after his arrest, Haynes signed a written confession.
- Even after signing the confession and appearing before a magistrate, Haynes was held incommunicado for a total of five to seven days before he was finally permitted to call his wife.
Procedural Posture:
- Raymond L. Haynes was charged with robbery in a Superior Court of the State of Washington (the trial court).
- At trial, the court admitted Haynes's written confession into evidence over his counsel's objection.
- The issue of the confession's voluntariness was submitted to the jury, which returned a general verdict of guilty.
- Haynes appealed his conviction to the Supreme Court of Washington (the state's highest court).
- The Supreme Court of Washington affirmed the conviction.
- The United States Supreme Court granted certiorari to review the case.
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Issue:
Does the admission of a written confession into evidence violate the Due Process Clause of the Fourteenth Amendment when the confession was obtained after police held the suspect incommunicado for 16 hours and refused his requests to contact his wife until he provided a signed statement?
Opinions:
Majority - Justice Goldberg
Yes, the admission of the written confession violates the Due Process Clause. A confession is involuntary if the defendant's will was overborne at the time he confessed. The undisputed facts show that Haynes's confession was obtained in an atmosphere of substantial coercion created by police actions. Confronted with the express threat of continued incommunicado detention and induced by the promise of communication with his family, Haynes's choice to confess cannot be considered the voluntary product of a free and unconstrained will. The Court has an independent duty to review the record to determine voluntariness, and it is not bound by a state court or jury's finding, especially where, as here, the jury instructions on the issue were constitutionally questionable.
Dissenting - Justice Clark
No, the admission of the confession does not violate the Due Process Clause. The Court's reversal is an abrupt departure from precedent. Haynes was a mature adult with a significant criminal history, not a naive or vulnerable individual susceptible to coercion. He spontaneously made two oral confessions immediately following his arrest, long before the written statement was made. Given his age, intelligence, experience with police, and the absence of physical abuse or prolonged interrogation, the police conduct of holding him incommunicado and promising he could call his wife after being booked did not overbear his will or render the confession involuntary.
Analysis:
This case significantly reinforces the 'totality of the circumstances' test for determining the voluntariness of a confession under the Due Process Clause. It clarifies that psychological coercion, such as the threat of indefinite incommunicado detention, can be as constitutionally impermissible as physical force. The decision underscores that a confession's voluntariness is a federal constitutional question subject to independent review by the Supreme Court, regardless of state court findings. This ruling helped pave the way for later decisions like Miranda v. Arizona, which established more concrete procedural safeguards against coercive interrogation techniques.
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