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Lisenba v. California

United States Supreme Court

314 U.S. 219 (1941)

Relevant factsFree

Robert James (defendant) confessed to murdering his wife after being held in police custody for nearly two days without arraignment or counsel, and while it was undisputed the police illegally denied him counsel, failed to promptly arraign him, and had no clear authority to remove him from jail for a second, over-12-hour interrogation session without his attorney, only one slap was corroborated despite James's broader claims of being beaten. James didn't mention any mistreatment beyond that single slap until trial, even when directly asked at the time how police were treating him. After a co-suspect, Hope, was arrested and made statements implicating James, police re-interrogated James for over 12 hours without counsel, during which he ultimately gave his own account placing Hope as the scheme's mastermind; James claimed he confessed only after an officer threatened him, while the state maintained he confessed after an officer offered to take him to get food. The trial court found the confession voluntary and admitted it.

IssueFree

Whether a confession made in violation of state law necessarily amounts to a denial of due process requiring its exclusion at trial.

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