## Facts

- Zelma Ida Ashcraft disappeared near Memphis, Tennessee, on June 5, 1941, while driving toward Kentucky; her car was later found, and she was subsequently found murdered.
- Tennessee prosecuted E. E. Ashcraft on the theory that he hired John Ware to kill his wife.
- The prosecution’s case relied heavily on alleged confessions by Ashcraft and Ware.
- Ashcraft was held incommunicado for about 36 hours and questioned continuously by relays of officers and an investigator without sleep or rest.
- Ware asserted that he confessed out of fear of mob violence.
- At their joint murder trial, the judge submitted voluntariness of the confessions to the jury; the Tennessee courts did not make an explicit, independent judicial finding that the confessions were voluntary.
- Both defendants were convicted and sentenced to 99 years’ imprisonment; the Tennessee Supreme Court affirmed.

## Issues

1. Whether Ashcraft’s alleged confession was involuntary due to coercive interrogation conditions, making its admission a violation of the Fourteenth Amendment Due Process Clause.
2. Whether, in due process challenges to state convictions based on allegedly coerced confessions, the Supreme Court must independently review voluntariness notwithstanding a state court finding or jury verdict.

## Decision

- The Supreme Court reversed Ashcraft’s conviction, holding that, on the undisputed evidence, any confession obtained under the 36-hour incommunicado, sleepless interrogation was compelled and not voluntary.
- The Court held that it must independently examine the entire record on a coerced-confession due process claim and that this duty is not displaced by state-court determinations or a jury’s voluntariness verdict.
- Because Ware’s affirmance in state court rested on assumptions tied to the validity of Ashcraft’s confession, the Court vacated Ware’s judgment and remanded for further proceedings consistent with the ruling as to Ashcraft.

## Legal Principles

- The Fourteenth Amendment’s Due Process Clause prohibits a state from obtaining or sustaining a conviction through the use of a coerced confession.
- In reviewing a coerced-confession due process claim arising from a state conviction, the Supreme Court has an obligation to conduct an independent examination of the record; state findings and a jury verdict do not foreclose federal constitutional review.
- Prolonged incommunicado interrogation, conducted continuously by relays of questioners and depriving the suspect of sleep and rest, is inherently coercive and renders any resulting confession involuntary as a matter of constitutional law.
- Coercion for due process purposes may be mental as well as physical; the controlling question is whether the defendant’s will was overborne under the totality of the circumstances.

## Conclusion

The Court set aside a conviction that depended on a confession extracted through 36 hours of incommunicado, uninterrupted, sleepless questioning, and it reaffirmed that federal courts must independently determine voluntariness when a state conviction is challenged as resting on a coerced confession under the Fourteenth Amendment.


Ashcraft v. Tennessee, 322 U.S. 143 (1944)