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Law School Case Brief

Haley v. Ohio - 332 U.S. 596, 68 S. Ct. 302 (1948)

Rule:

If the undisputed evidence suggests that force or coercion was used to exact a confession, the court will not permit the judgment of conviction to stand, even though without the confession there might have been sufficient evidence for submission to the jury. 

Facts:

A confectionery store was robbed and its owner was shot. There was evidence that defendant Haley, a 15-year-old boy, acted as a lookout, and he was arrested. Beginning after midnight, without counsel or the advisement of his right thereto, he was questioned by the police for about five hours. Then, after being shown two other boys' alleged confessions, he confessed. He was not allowed to see his mother nor the lawyer she retained for him, although a newspaper photographer was allowed to take his picture immediately after the confession. He was not taken before a magistrate and formally charged until three days after he confessed. Haley was convicted of first degree murder in state court; the conviction was affirmed by an appellate court and the state supreme court.

Issue:

Was Haley's confession obtained in violation of the due process requirements of the Fourteenth Amendment?

Answer:

Yes.

Conclusion:

The Supreme Court of the United States held that the methods used in obtaining the confession violated the due process requirements of the Fourteenth Amendment. Haley's age, the hours when he was questioned, the duration of the questioning, the fact that he had no friend or counsel to advise him, and the callous attitude of the police convinced the Court that the confession was wrung from a child by means which the law should not sanction.

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