Today in 1940: SCOTUS rules that confessions obtained by police coercion are inadmissible

February 12, 2016

Today in Legal HistoryA commonly used trope in police dramas is a suspect sitting in a police interrogation room with one or more law enforcement officers.  The officers are attempting to pressure the suspect into confessing to a crime, often using aggressive tactics to do so.

As any criminal defense attorney would tell you, there are a number of procedural problems with this scenario as it’s often portrayed – not least among them is the absence of the suspect’s counsel during the questioning.  But another such procedural flaw in this trope is that any confessions compelled by police through duress are inadmissible as evidence.

The case responsible for this rule, Chambers v. Florida, is celebrating its 76th birthday today.  Decided by a unanimous Supreme Court on February 12, 1940, the facts of Chambers begin with the police interrogation trope – albeit one that is far more extreme and racially charged.

The night of Saturday, May 13, 1933, Robert Darcy, “an elderly white man, was robbed and murdered in Pompano, Florida.”  The Supreme Court of Florida wrote that the crime “induced an enraged community,” such that police were under public pressure to find the culprit (or a scapegoat, apparently it didn’t much matter).  Consequently, within an hour of the murder, “twenty-five to forty negroes living in the community, including [the petitioners], were arrested without warrants and confined in the Broward County jail, at Fort Lauderdale.”

The four petitioners, described by the Court as “ignorant young colored tenant farmers,” along with several others, were subjected to five days of constant questioning, culminating in a full night of interrogation.  These was disputing testimony on the issue, but the petitioners claimed that they were “continually physically mistreated” and threatened – with one claiming that he was told that he “would never see the sun rise” if he didn’t confess.

Finally, the petitioners all eventually “broke” and “confessed” to the murder.  The petitioners were convicted and sentenced to death.  The petitioners filed a petition for a writ of error, claiming that the confessions were the result of police coercion, and were thus inadmissible.  The Florida supreme court affirmed the convictions, and the U.S. Supreme Court agreed to review the case.

In an opinion by Justice Hugo Black, the Court overturned the state supreme court ruling, and thus the petitioners’ convictions.  The Court found that, even without considering any issues of physical violence and mistreatment (on which the record was inconclusive), the circumstances of the questioning – warrantless arrests, “protracted questioning and cross questioning,” and held “without friends, advisers or counselors, and under circumstances calculated to break the strongest nerves and the stoutest resistance” – the confessions were undoubtedly the result of compulsion.

At a time when the Fifth Amendment was only minimally incorporated against the states (indeed, it was only seven years later that the Court held in Adamson v. California that a defendant’s right to not bear witness against himself did not apply in state court), it was a truly landmark holding in Chambers for the Court to find that:

the due process provision of the Fourteenth Amendment—just as that in the Fifth—has led few to doubt that it was intended to guarantee procedural standards adequate and appropriate, then and thereafter, to protect, at all times, people charged with or suspected of crime by those holding positions of power and authority.

Chambers further denotes one of the first instances that the Court held that police conduct short of physical violence should result in the suppression of evidence, and its holding helped pave the way for some of the most significant cases in criminal procedure (namely, Miranda v. Arizona).

So the next time you are watching a police drama with a particularly aggressive interrogation, you can snidely remark, “You know, any confession obtained by police coercion wouldn’t be admissible in court,” while then awaiting the inevitable responses of eye rolls and annoyed groans from your fellow viewers.