Watts v. Indiana 338 U.S. 49, 69 S. Ct. 1347, 93 L. Ed. 1801 (1949)
Watts was arrested on
suspicion of assault and murder. The police put him in a bare room with
no furniture and questioned him on and off for 6 straight days.
Eventually he confessed.
He was given no hearing or
legal counsel during this time.
The Trial Court convicted
Watts of murder. He appealed.
The Indiana Supreme Court
upheld the conviction. Watts appealed.
The US Supreme Court reversed.
The US Supreme Court found
that the confession was inadmissible because it was not voluntary.
"A confession by which
life becomes forfeit must be the expression of free choice. A statement
to be voluntary of course need not be volunteered. But if it is the
product of sustained pressure by the police it does not issue from a
free choice."
The Court noted that the
American legal system is an accusatorial system, not an inquisitorial
system.
The Court found that the Due
Process Clause of the 14th
Amendment bars police procedure which "violates our basic
notions of our accusatorial mode of prosecuting crime and vitiates a
conviction based on the fruits of such procedure."
In a concurrence, it was
argued that there are some situations (like this one), in which the police
tactic goes too far, and other case (like the companion cases Harris v.
South Carolina, and Turner
v. Pennsylvania) in which it doesn't.
The courts should balance the rights of the accused with the needs of law
enforcement to solve crimes on a case-by-case basis, and not establish any
bright-line rules.
On reason to throw out
involuntary confessions is that they are unreliable. But Watts gave
detailed information that was corroborated by other evidence, so his
confession turned out to be very reliable.
The across the board
prohibition was to deter conduct in other cases that could lead to unreliable confessions.
Also, the State should not
be overriding a person's free will. That's evil, even if it is shown to
prove reliable results.