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Law School Case Brief

Jackson v. Denno - 378 U.S. 368, 84 S. Ct. 1774 (1964)

Rule:

A defendant in a criminal case is deprived of due process of law if his conviction is founded, in whole or in part, upon an involuntary confession, without regard for the truth or falsity of the confession and even though there is ample evidence aside from the confession to support the conviction. Equally clear is the defendant's constitutional right at some stage in the proceedings to object to the use of the confession and to have a fair hearing and a reliable determination on the issue of voluntariness, a determination uninfluenced by the truth or falsity of the confession.

Facts:

Petitioner, after robbing a hotel, fatally wounded a policeman and himself received two bullet wounds. Questioned shortly after arrival at a hospital, he admitted the shooting and the robbery. Some time later, after considerable loss of blood and soon after he had been given drugs, he was interrogated and admitted firing the first shot at the policeman. Petitioner was indicted for murder and both statements were admitted at the trial, at which petitioner's testimony differed in some important respects from the confessions. In accord with New York practice where the voluntariness of a confession is attacked, the trial court submitted that issue, with the others, to the jury. The jury was told to disregard the confession entirely if it was found involuntary, and to determine the guilt or innocence solely from other evidence; or, if it found the confession voluntary, it was to determine its truth or reliability and weigh it accordingly. The jury found petitioner guilty of first-degree murder, the New York Court of Appeals affirmed and this Court denied certiorari. Petitioner filed a petition for a writ of habeas corpus asserting that the New York procedure for determining voluntariness of a confession was unconstitutional and that his confession was involuntary. The District Court denied the petition and the Court of Appeals affirmed.

Issue:

Was the state’s procedure of submitting the issue of the confession’s voluntariness to the jury satisfactory with regard to Due Process and Fourteenth Amendment requirements?

Answer:

No.

Conclusion:

The Court held that the state procedure of submitting the issue of the confession's voluntariness to the jury did not satisfy the Due Process and Fourteenth Amendment requirements. According to the Court, under the New York procedure, the evidence given the jury inevitably injects irrelevant and impermissible considerations of truthfulness of the confession into the assessment of voluntariness. Alternatively there was the danger that a confession found to be coerced played some part in the jury's deliberations on guilt or innocence. As such, petitioner was entitled to a state court hearing on the issue of the voluntariness of the confession by a body other than the one trying his guilt or innocence but that does not necessarily entitle him to a new trial.

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