## Facts

- Johnny Daniel Beecher escaped from an Alabama prison road gang on June 15, 1964; the next day a woman’s body was found near the prison camp.
- Beecher was captured in Tennessee after being shot in the leg while fleeing.
- During capture, officers held a gun to Beecher’s face and a rifle to his head; he was threatened with death, a rifle was fired near his ear, and he confessed.
- Beecher was later transported to an Alabama prison hospital; his wound worsened and ultimately required amputation.
- While hospitalized, he received morphine injections for severe pain roughly every four hours.
- Less than an hour after a morphine injection, Alabama investigators questioned him for about 90 minutes and prepared two written statements similar to the earlier gunpoint confession.
- At trial for first-degree murder, the State introduced the written confessions over Beecher’s objection that they were coerced; he was convicted and sentenced to death.
- The Alabama Supreme Court affirmed the conviction and sentence.

## Issues

1. Whether admitting Beecher’s confessions—obtained under death threats at gunpoint and later during hospital interrogation while severely wounded and under morphine—violated the Fourteenth Amendment Due Process Clause.

## Decision

- The Supreme Court reversed the judgment affirming Beecher’s conviction and death sentence.
- The Court held the confessions were the product of “gross coercion” and their use at trial violated due process.
- The Court treated the later hospital confessions as tainted by the earlier gunpoint coercion because there was no sufficient break in the sequence of events.
- The Court rejected the State’s procedural objection that the voluntariness challenge was untimely, noting Beecher objected at trial.
- The Court did not address other constitutional claims because the coerced-confession issue was dispositive.

## Legal Principles

- A confession is inadmissible under the Fourteenth Amendment Due Process Clause if obtained by coercion, including threats of immediate death or violence.
- Later statements may be inadmissible when there is no meaningful break separating them from earlier coercion, so that the coercive influence continues.
- Severe physical injury, interrogation in a custodial medical setting, and questioning while under the influence of powerful pain medication can contribute to a finding that a confession was involuntary.

## Conclusion

The Court held that confessions extracted through extreme coercion—beginning with a gunpoint death threat and continuing through later hospital interrogation of a wounded, morphine-medicated prisoner without a sufficient break—are involuntary and cannot be used to sustain a conviction consistent with due process.


Beecher v. Alabama, 389 U.S. 35 (1967)