Watts v. Indiana
338 U.S. 49 (1949)
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Rule of Law:
A confession obtained through sustained and coercive psychological pressure, such as prolonged interrogation over several days while a suspect is held incommunicado without a prompt hearing or legal counsel, is involuntary and its admission into evidence violates the Due Process Clause of the Fourteenth Amendment.
Facts:
- On November 12, 1947, police arrested petitioner Watts on suspicion of criminal assault.
- Later that day, a woman was found murdered nearby, and suspicion shifted to Watts for that crime.
- For six days, with one day of rest, police held Watts without bringing him before a magistrate for a preliminary hearing as required by Indiana law.
- For the first two days, Watts was held in solitary confinement in a cell known as 'the hole'.
- On five of those nights, police transported Watts to State Police Headquarters and interrogated him in relays from evening until early morning, for approximately seven to nine hours at a time.
- During his detention, Watts was not advised of his constitutional rights and did not have access to friends, family, or legal counsel.
- Around 3:00 AM on the morning of November 18, after hours of continuous questioning, Watts made an incriminating statement, which was followed by a more detailed confession elicited by a prosecutor.
Procedural Posture:
- Watts' confession was admitted into evidence at his trial in an Indiana state court.
- A jury convicted Watts of murder.
- Watts appealed his conviction to the Supreme Court of Indiana, arguing his confession was coerced.
- The Supreme Court of Indiana (appellee) affirmed the conviction, finding the confession was voluntary.
- Watts (petitioner) petitioned the Supreme Court of the United States for a writ of certiorari, which was granted.
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Issue:
Does the use of a confession at trial, obtained after a suspect was held for six days without a preliminary hearing and subjected to prolonged, relentless interrogation by relays of police officers, violate the Due Process Clause of the Fourteenth Amendment?
Opinions:
Majority - Justice Frankfurter
Yes. The use of this confession violates the Due Process Clause of the Fourteenth Amendment because it was not the product of a free and voluntary choice. A confession must be the expression of a free choice, and sustained pressure by the police that overbears the suspect's will renders a confession involuntary. The court's reasoning is rooted in the distinction between the American accusatorial system of justice and the inquisitorial system. Under our accusatorial system, the government must prove its case through independent investigation, not by wrenching evidence from the accused's own mouth through a 'suction process' of relentless interrogation. The undisputed circumstances—prolonged interrogation in relays, denial of a prompt hearing, and isolation from counsel—constitute a 'torture of mind' that is as coercive as physical force and offends the procedural standards of due process.
Concurring - Justice Douglas
Yes. The confession should be held inadmissible because it was obtained during a period of unlawful detention. This 'protective custody' was nothing less than an inquisition where the suspect was held until he broke. The procedure of detention without arraignment is the 'root of the evil' because it keeps the accused under the exclusive control of the police, without the aid of counsel or the protection of a magistrate. The Court should unequivocally condemn this practice and outlaw any confession obtained during such unlawful detention.
Concurring - Justice Jackson
Yes. While acknowledging the difficulty police face in solving unwitnessed murders, the procedure used here violates due process. The most serious issue is that the suspect neither had nor was advised of his right to counsel. Subjecting an uncounseled individual to questioning intended to convict him is a grave peril to individual freedom. Although bringing in a lawyer may impede solving the crime, our system prioritizes protecting the accused. The combination of factors, especially the lack of counsel during prolonged interrogation, rendered the process unconstitutional.
Analysis:
This case is a landmark pre-Miranda decision that solidifies the application of the 'totality of the circumstances' test to determine the voluntariness of a confession under the Fourteenth Amendment's Due Process Clause. It significantly broadens the concept of coercion to include psychological pressure, establishing that a confession can be involuntary even without evidence of physical violence. The decision strongly affirms the principles of the accusatorial system, limiting the power of police to use prolonged incommunicado interrogation to extract confessions. This ruling paved the way for future decisions that would establish more concrete procedural safeguards for suspects during custodial interrogation.
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