Watts v. Indiana - 338 U.S. 49, 69 S. Ct. 1347 (1949)

Rule:

Under the accusatorial system of criminal law, society carries the burden of proving its charge against the accused not out of his own mouth. It must establish its case, not by interrogation of the accused even under judicial safeguards, but by evidence independently secured through skillful investigation. The requirement of specific charges, their proof beyond a reasonable doubt, the protection of the accused from confessions extorted through whatever form of police pressures, the right to a prompt hearing before a magistrate, the right to assistance of counsel, to be supplied by government when circumstances make it necessary, the duty to advise an accused of his constitutional rights -- these are all characteristics of the accusatorial system and manifestations of its demands. Protracted, systematic and uncontrolled subjection of an accused to interrogation by the police for the purpose of eliciting disclosures or confessions is subversive of the accusatorial system. It is the inquisitorial system without its safeguards. In holding that the Due Process Clause bars police procedure which violates the basic notions of our accusatorial mode of prosecuting crime and vitiates a conviction based on the fruits of such procedure, the Supreme Court applies the Due Process Clause to its historic function of assuring appropriate procedure before liberty is curtailed or life is taken.

Facts:

Petitioner Watts was arrested on suspicion on a Wednesday and held without arraignment, without the aid of counsel or friends and without advice as to his constitutional rights, until the following Tuesday, when he confessed to murder. Meanwhile he was held much of the time in solitary confinement in a cell with no place to sit or sleep except the floor and was interrogated by relays of police officers, usually until long past midnight. At his trial in a state court, the confession was admitted in evidence over his objection and he was convicted. Petitioner sought certiorari to review the judgment of the state court.

Issue:

Under the circumstances, were the petitioner’s confessions admissible as evidence, thereby warranting his conviction?

Answer:

No.

Conclusion:

The Court held that the use, at a trial for murder in a state court, of a confession obtained by relentless police interrogation while in solitary confinement, without the aid of counsel or friends and without advice as to his constitutional rights, was a violation of the Due Process Clause of the Fourteenth Amendment. According to the Court, due process required that a confession by which life would become forfeit must be the expression of free choice; and, while a statement to be voluntary need not be volunteered, it did not issue from a free choice if it was a product of a sustained pressure by the police, it being immaterial whether the accused has been subjected to a physical or a mental ordeal. Accordingly, the Court reversed the judgment of the state court.