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Law School Case Brief

Ashcraft v. Tennessee - 322 U.S. 143, 64 S. Ct. 921 (1944)

Rule:

It is inconceivable that any court of justice in the land, conducted as our courts are, open to the public, would permit prosecutors serving in relays to keep a defendant witness under continuous cross-examination for 36 hours without rest or sleep in an effort to extract a "voluntary" confession. Nor can the United States Supreme Court, consistently with Constitutional due process of law, hold voluntary a confession where prosecutors do the same thing away from the restraining influences of a public trial in an open court room. 

Facts:

Petitioner inmates filed petitions for certiorari that challenged their convictions for murder and accessory before the fact, alleging that the alleged confessions used at their trial had been extorted from them by state law enforcement officers in violation of U.S. Const. amend. XIV. Inmates Ware and Ashcraft urged that the "confessions" that were used at their trial had been extorted from them by state law enforcement officers in violation of the Fourteenth Amendment, and that "solely and alone" on the basis of these confessions they had been convicted. Their contentions raised a federal question which the record showed to be substantial and we brought both cases here for review. Upon oral argument before this Court Tennessee's legal representatives conceded that the convictions could not be sustained without the confessions but defended their use upon the ground that they were not compelled but were "freely and voluntarily" made.

Issue:

Were the confessions obtained after police questioned a subject for more than 36 hours straight violated Fourteenth Amendment, and thus inadmissible?

Answer:

Yes

Conclusion:

The United States Supreme Court reversed the state supreme court's judgment that affirmed the convictions against petitioner inmates because, based on the totality of the circumstances, petitioners' confessions were not voluntary but compelled. U.S. Const. amend. XIV barred a conviction of any individual obtained by means of a coerced confession. Inquiries among his neighbors and business associates likewise had failed to unearth one single tangible clue pointing to his guilt. For 36 hours after Ashcraft's seizure during which period he was held incommunicado, without sleep or rest, relays of officers, experienced investigators, and highly trained lawyers questioned him without respite. From the beginning of the questioning at 7 o'clock on a Saturday evening until 6 o'clock on Monday morning, Ashcraft denied that he had anything to do with the murder of his wife. And at a hearing before a magistrate about 8:30 Monday morning Ashcraft pleaded not guilty to the charge of murder which the officers had sought to make him confess during the previous 36 hours. The situation such as that here shown by uncontradicted evidence is so inherently coercive that its very existence is irreconcilable with the possession of mental freedom by a lone suspect against whom its full coercive force is brought to bear.

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