Due Process Limitations Fifth Amendment Flashcards
Ashcraft v Tennesee
Facts
Mrs. Zelma Ida Ashcraft was found dead on the side of a road, a victim of murder. Ware, a 20-year-old African American, and Ashcraft, a 45-year-old white man and the husband of the deceased, were indicted, tried, and convicted in connection with her murder. Ashcraft was convicted as an accessory before the fact, with both receiving sentences of ninety-nine years. Their convictions were largely based on alleged confessions obtained during interrogations by state law enforcement officers. These confessions were challenged as being extorted in violation of the Fourteenth Amendment. The interrogation of Ashcraft involved a continuous, thirty-six-hour session without sleep or rest, conducted in secret by relays of officers. The Tennessee courts did not definitively find these confessions voluntary but allowed them to be used in the trial.
Issue
Were the confessions obtained from Ashcraft and Ware in violation of the Fourteenth Amendment due to the coercive nature of the interrogations?
Holding
The United States Supreme Court reversed Ashcraft’s conviction and vacated Ware’s conviction, remanding his case for further proceedings consistent with the opinion.
Reasoning
The Court conducted an independent examination of the circumstances under which the confessions were obtained, as required by federal law, regardless of state court findings. The Court concluded that Ashcraft’s confession, if made, was not voluntary but compelled, given the inherently coercive situation of a thirty-six-hour continuous interrogation without sleep or rest. The Court emphasized that such a practice is irreconcilable with the possession of mental freedom by a lone suspect and is in conflict with the principles of due process and the prohibition of coerced confessions. The Court also pointed out the significant difference between conducting such an interrogation in the privacy of a police station and the openness and fairness expected in a trial in an American court. The treatment of Ware’s case by the state courts was contingent on Ashcraft’s confession being admissible. Since the Supreme Court reversed Ashcraft’s conviction due to the involuntary nature of his confession, it vacated Ware’s conviction and remanded his case for reconsideration by the Tennessee Supreme Court in light of the change in circumstances.
Lisenba v California
Facts
Robert S. James, known as the petitioner, was convicted of murder and sentenced to death in California for the killing of his wife, with the intent to collect life insurance benefits. James had planned the murder to appear as an accident, involving a scheme with an accomplice, Hope, to use rattlesnake bites and ultimately drowning to cause her death. Following his wife’s death, James attempted to collect the insurance payout. His conviction was based partly on his confessions and the testimony of Hope, who had turned state’s evidence. James contended that his confessions were coerced through physical violence and threats, and that Hope’s testimony was unreliable and induced by promises of leniency.
Issue
The issue was whether James’ conviction violated the Fourteenth Amendment due process clause, focusing on the admissibility and voluntariness of his confessions, the reliability of accomplice testimony, and the overall fairness of the trial.
Holding
The Supreme Court affirmed the conviction, holding that James was not deprived of due process under the Fourteenth Amendment. The Court found no fundamental unfairness in the trial process that would rise to a violation of due process.
Reasoning
The Court reasoned that the conduct of law enforcement, while disapproved, did not cross the line into coercion that would render James’ confessions involuntary or fundamentally unfair. Despite the extended and intense interrogation, there was no conclusive evidence that the confessions were obtained through coercive means that would violate due process. Additionally, the Court found that the corroborative testimony of the accomplice, Hope, was not inherently unreliable or coerced to the extent that it would affect the fairness of the trial. The Court also noted that state law violations related to James’ treatment and interrogation did not necessarily equate to a constitutional due process violation. The Supreme Court conducted an independent examination of the record and concluded that the trial’s use of James’ confessions and the evidence presented did not result in a denial of fundamental fairness or due process of law.
Connolly Note
Amendment V
No person shall be held to answer for a capital, or otherwise infamous crime, unless on a presentment or indictment of a Grand Jury, except in cases arising in the land or naval forces, or in the Militia, when in actual service in time of War or public danger; nor shall any person be subject for the same offence to be twice put in jeopardy of life or limb; nor shall be compelled in any criminal case to be a witness against himself, nor be deprived of life, liberty, or property, without due process of law; nor shall private property be taken for public use, without just compensation
