Greenwald v. Wisconsin - 390 U.S. 519, 88 S. Ct. 1152 (1968)

Rule:

The fact that an accused was deprived of sleep, food, and his medication, and requested counsel, under the United States Supreme Court decisions, is relevant to the claim that the statements were involuntary.

Facts:

Defendant was arrested on suspicion of burglary. He did not have his blood pressure medication with him. He was interrogated for several hours and was not advised of his constitutional rights. Defendant was eventually taken to a cell where the bed was a plank fastened to a wall. He claimed not to have slept. Four hours later, he was removed from the cell and placed in a lineup. Thereafter, the interrogation recommenced. He refused to answer questions for several hours, denied guilt, and said that he was entitled to an attorney when he was asked to write a confession. He finally began to confess. He was then advised of his constitutional rights. At a hearing, the trial court found that his statements were voluntary, although defendant testified that he only confessed because he knew that the officers would not leave him alone until he did. His conviction was affirmed on appeal. Defendant sought review of the judgment. 

Issue:

Under the circumstances, were the defendant’s statements voluntary? 

Answer:

No.

Conclusion:

On certiorari, the Court stated that it had a duty in such a situation to consider the totality of the circumstances surrounding the statements. In reversing, the Court held that the statements were involuntary due to the lack of counsel, the lack of warnings, and the lack of food, sleep, and medication. Accordingly, the court reversed the judgment of the lower court.