Law School Case Brief
Bram v. United States - 168 U.S. 532, 18 S. Ct. 183 (1897)
A confession, in order to be admissible, must be free and voluntary: that is, must not be extracted by any sort of threats or violence, nor obtained by any direct or implied promises, however slight, nor by the exertion of any improper influence. A confession can never be received in evidence where the prisoner has been influenced by any threat or promise; for the law cannot measure the force of the influence used, or decide upon its effect upon the mind of the prisoner, and therefore excludes the declaration if any degree of influence has been exerted.
Bram was accused of murdering a ship's captain and others while they slept aboard a ship en route to the United States. Based solely on a claim of a co-suspect, Brown, that he saw Bram commit the crime, Bram was arrested. At trial, a detective who had questioned Bram was permitted to testify about Bram's statements. Bram sought a writ of error.
Was Bram's confession made to the detective admissible?
The United States Supreme Court reversed the conviction on the ground that Bram's confession made to the detective was not voluntary, and, therefore, was improperly admitted. Bram was in custody when the detective, in an official capacity, directed the police authorities to bring Bram as a prisoner to a private office where Bram was stripped and searched. Bram understood that he was a prisoner and obeyed every order and direction that the detective gave. When confronted with Brown’s accusation, Bram feared that if he remained silent, it would be considered an admission of guilt. Thus, the facts, when taken together, were sufficient to warrant the inference that Bram was compelled to make a statement. As such, the statement was not voluntary and a new trial was necessary.
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