Miller v. Fenton

Detective Boyce interviewed Frank Miller (defendant), the prime suspect in a murder, adopting a friendly, sympathetic manner, falsely telling him the victim was still alive, and portraying himself as someone who just wanted to help Miller unburden his conscience rather than as a typical interrogator. Miller, a 32-year-old with some high school education and a prior record, remained guarded throughout and made remarks showing he understood he was in an ordinary police interrogation that could lead to criminal charges, but after about 30 minutes he began making incriminating statements and fully confessed an hour in before collapsing into unresponsive shock and being hospitalized. New Jersey courts disagreed over whether the resulting tape-recorded confession was voluntary, and on federal habeas review the U.S. Supreme Court held the federal court must independently review the voluntariness question rather than defer to the state court's finding, remanding for that redetermination.