Lisenba v. California

314 U.S. 219, 62 S. Ct. 280 (1941)

 

RULE:

As applied to a criminal trial, denial of due process is the failure to observe that fundamental fairness essential to the very concept of justice. In order to declare a denial of due process, a court must find that the absence of that fairness fatally infected the trial. The acts complained of must be of such quality as necessarily prevents a fair trial. 

FACTS:

Petitioner was charged with murder for the death of his wife. During trial, petitioner argued that the police officers of respondent State of California denied his right to due process under U.S. Const. amend. XIV by extorting his confession by coercive means, and thus, the statement should not be admitted in court.  After a hearing, the trial judge admitted the confession, and the jury convicted petitioner of murder. The state appellate courts affirmed the conviction and denied the writ of habeas corpus. Petitioner appealed.

ISSUE:

By allegedly extorting petitioner’s confession through coercive means, did the police officers violate petitioner’s right to due process?

ANSWER:

No.

CONCLUSION:

The Court acknowledged that when the officers failed to produce petitioner before a magistrate, detained him for days, assaulted him, and denied him access to counsel, they violated state law. However, the Court held that these illegal acts did not determine whether a due process violation had occurred. According to the Court, the issue was whether the use of the confession resulted in an unfair trial. The purpose of excluding involuntary confessions was to exclude false evidence, but the aim of due process was to exclude any evidence the use of which would be fundamentally unfair. In the case at bar, the evidence about how petitioner's confession was obtained was conflicting, and the Court could not find that the lower court's findings were erroneous. The Court affirmed the state supreme court's decision to deny the writ of habeas corpus. Although the behavior of the police officers of respondent State of California in procuring the confession of petitioner fell within the definition of criminal conduct under state law, the trial court and jury found that the confessions were voluntary. The Court's review of the record did not contradict these findings.

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