Lego v. Twomey
404 U.S. 477 (1972)
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Rule of Law:
The Due Process Clause of the Fourteenth Amendment does not require the prosecution to prove the voluntariness of a confession beyond a reasonable doubt. The prosecution must prove voluntariness by a preponderance of the evidence for the confession to be admissible in a criminal trial.
Facts:
- Lego was arrested for armed robbery and made a confession to police while in custody.
- Lego later claimed that police officers had beaten him about the head and neck with a gun butt to coerce the confession.
- He alleged the local police chief, who was a neighbor of the robbery victim, sought revenge on him.
- Lego introduced a photograph taken the day after his arrest that showed his face was swollen with traces of blood.
- Lego admitted his face was scratched during a scuffle with the robbery victim, but argued this did not explain the condition shown in the photograph.
- The police chief and four other officers testified, denying they had beaten or threatened Lego.
Procedural Posture:
- Lego was tried for armed robbery in the Superior Court of Cook County, Illinois (trial court).
- Prior to trial, Lego moved to suppress his confession as involuntary.
- The trial judge held a hearing, found the confession voluntary by a preponderance of the evidence as required by Illinois law, and ruled it admissible.
- A jury convicted Lego, and he was sentenced to prison.
- Lego, as appellant, appealed his conviction to the Illinois Supreme Court (state's highest court), which affirmed.
- Lego later filed a petition for a writ of habeas corpus in the U.S. District Court for the Northern District of Illinois (federal court of first instance).
- The District Court denied the petition on the merits.
- Lego, as appellant, appealed to the U.S. Court of Appeals for the Seventh Circuit (federal intermediate appellate court), which affirmed the District Court's decision.
- The U.S. Supreme Court granted certiorari to resolve the question of the required standard of proof.
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Issue:
Does the Due Process Clause of the Fourteenth Amendment require the prosecution to prove the voluntariness of a confession beyond a reasonable doubt before it can be admitted as evidence at trial?
Opinions:
Majority - Justice White
No. The prosecution is only required to prove the voluntariness of a confession by a preponderance of the evidence. The purpose of a voluntariness hearing is not to enhance the reliability of the jury's verdict on guilt or innocence, but to safeguard a defendant's right against self-incrimination and to deter police misconduct. The 'beyond a reasonable doubt' standard established in In re Winship applies only to the facts necessary to constitute the crime charged, not to preliminary determinations of the admissibility of evidence. The public interest in placing probative evidence before the jury outweighs the minimal additional deterrent effect that a higher standard of proof might provide. States remain free to adopt a higher standard under their own laws, but the Constitution only mandates the preponderance standard.
Dissenting - Justice Brennan
Yes. The rationale of Jackson v. Denno and the fundamental values protected by the Fifth Amendment require the prosecution to prove a confession was voluntary beyond a reasonable doubt. A preponderance of the evidence standard is insufficient protection against the significant risk of admitting coerced confessions. The same societal value determination that it is 'far worse to convict an innocent man than to let a guilty man go free,' which underpins the reasonable-doubt standard for guilt, should apply here. It is worse to permit involuntary self-condemnation than it is to deprive a jury of potentially probative evidence, and a lower standard of proof fails to give 'concrete substance' to the Fifth Amendment's command.
Analysis:
This decision establishes the constitutional floor for the standard of proof in suppression hearings regarding confessions, setting it at a preponderance of the evidence. It distinguishes between the standard required for proving the elements of a crime (Winship's 'beyond a reasonable doubt') and the standard for preliminary evidentiary matters. By doing so, the Court made it easier for prosecutors to admit challenged confessions into evidence than if a higher standard were required. This ruling solidifies the role of the judge as the gatekeeper of evidence based on a lower burden of proof, separating that function from the jury's ultimate role in determining guilt based on a much higher standard.
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