McNabb v. United States - 318 U.S. 332, 63 S. Ct. 608 (1943)

Rule:

The principles governing the admissibility of evidence in federal criminal trials have not been restricted to those derived solely from the Constitution. In the exercise of its supervisory authority over the administration of criminal justice in the federal courts, the Supreme Court has, from the very beginning of its history, formulated rules of evidence to be applied in federal criminal prosecutions. And in formulating such rules of evidence for federal criminal trials, the Court has been guided by considerations of justice not limited to the strict canons of evidentiary relevance.

Facts:

Immediately upon the arrest of defendants for the alleged murder of an officer of the Alcohol Tax Unit of the Bureau of Internal Revenue, they were taken directly to the Federal Building at Chattanooga. They were not brought before a United States commissioner or a judge. Instead, they were placed in a detention room, and kept there for about fourteen hours. They had no lawyer. There was no evidence that they requested the assistance of counsel, or that they were told that they were entitled to such assistance. Admissions were obtained from the defendants, and the government charged the defendants with the crime of murder. The trial court admitted the defendants’ admissions as evidence, and they were subsequently convicted. The Court of Appeals affirmed the defendants’ convictions. Certiorari was granted. 

Issue:

Were the incriminating statements obtained under the circumstances admissible as evidence against the defendants? 

Answer:

No.

Conclusion:

The Court held that defendants' admissions were improperly received in evidence against them and, having been based on the admissions, the convictions could not stand. According to the Court, the principles governing the admissibility of evidence were not restricted to those derived solely from the Constitution. Defendants were questioned while they were in custody and before any order of commitment was made, in flagrant disregard of procedure. The arresting officers were required by 18 U.S.C.S. § 595 to take defendants before the nearest judicial officer having jurisdiction under existing laws for a hearing, commitment, or taking bail for trial. The arresting officers instead subjected defendants to the pressures of a procedure that was wholly incompatible with the arresting officers' duties and that tended to undermine the integrity of the criminal proceeding. Accordingly, the Court reversed the defendants’ convictions.