Spano v. New York
United States Supreme Court
360 U.S. 315 (1959)
Vincent Spano (defendant), a 25-year-old with no criminal history but a documented history of emotional instability, turned himself in with his attorney after a shooting, and his attorney left him in custody after specifically instructing him not to answer questions; police nonetheless interrogated Spano for nearly eight straight hours, repeatedly denying his invocations of his right to remain silent and his requests for his attorney, and eventually brought in Gaspar Bruno, an old friend of Spano's who had become a police officer, to falsely claim he would lose his job unless Spano confessed. After Bruno's fabricated appeals to their friendship finally broke Spano down, he confessed and answered leading prosecutorial questions; the trial court admitted the confession with an instruction that the jury consider it only if voluntary, the jury convicted Spano and sentenced him to death, and the New York Court of Appeals affirmed before the Supreme Court granted certiorari.
Whether a confession made after hours of interrogation, during which the defendant has been denied his right to counsel, is made voluntarily.