## Facts

- Johnny Daniel Beecher was shot in the leg while fleeing and was confronted by Tennessee officers who held a loaded gun to his face and a rifle to his head.
- Officers threatened to kill him if he did not confess; after a shot was fired near his ear, he immediately confessed in the field.
- About one hour after arrest, while hospitalized in Tennessee, Beecher made an oral confession to a doctor.
- At the time of the hospital statement, Beecher was in extreme pain from the gunshot wound and under the influence of morphine.
- After a prior Supreme Court reversal invalidating later written confessions obtained in Alabama under coercive circumstances, Alabama retried Beecher for first-degree murder and, at the second trial, used the Tennessee hospital oral confession instead of the written confessions.
- The Alabama Supreme Court affirmed the conviction, holding the hospital oral confession admissible.

## Issues

1. Whether Beecher’s oral confession made in a hospital one hour after arrest, while in extreme pain and under morphine and following earlier threats at gunpoint, was voluntary under the Fourteenth Amendment Due Process Clause.
2. Whether the hospital oral confession was inadmissible because it was part of the same continuous coercive sequence (“stream of events”) as the earlier coercion.

## Decision

- The Supreme Court reversed the judgment affirming Beecher’s conviction.
- The Court held the hospital oral confession was involuntary and inadmissible.
- The Court concluded the oral confession was the product of gross coercion and part of the same “stream of events” that required exclusion of Beecher’s other confessions.

## Legal Principles

- Due process bars admission of a confession obtained through gross coercion, including threats of death, violence, and exploitation of severe pain and drug-impaired condition.
- A later confession may be tainted and inadmissible when it follows closely in time and circumstance from prior coercion and is part of a single continuous “stream of events,” even if made to a different listener or in a different setting.
- The State bears the risk that coercive conditions that overbore the suspect’s will render related statements unreliable and constitutionally invalid.

## Conclusion

The Supreme Court held that Beecher’s hospital oral confession, made shortly after being threatened at gunpoint and while in extreme pain under morphine, was involuntary under due process and could not be used to sustain his conviction because it was inseparable from the same continuing coercive events.


Beecher v. Alabama, 408 U.S. 234 (1972)