## Facts

- On July 5, 1955, Crooker’s employer (with whom he had an illicit relationship) was found stabbed and strangled to death in her Los Angeles home.
- Crooker was arrested around 1:30 p.m. and interrogated intermittently for about 14 hours at his apartment and later at a police station.
- During questioning, Crooker repeatedly requested to contact counsel; police denied the requests until after he wrote a confession.
- Crooker received food and drink, was allowed to smoke, refused a lie detector test, and declined to answer many questions; an officer told him he need not answer questions he did not wish to answer.
- Around 2:00 a.m. on July 6, Crooker wrote a full written confession.
- Later that morning Crooker refused to repeat the confession orally, again requested an attorney, and was then allowed counsel.
- At trial, the jury found the confession voluntary; Crooker was convicted of first-degree murder and sentenced to death.
- The California Supreme Court affirmed; the U.S. Supreme Court granted review due to due process concerns regarding denial of access to counsel.

## Issues

1. Whether Crooker’s confession was involuntary under the Fourteenth Amendment Due Process Clause because it was coerced.
2. Whether denial of Crooker’s repeated requests to consult counsel during pretrial interrogation, even if the confession was otherwise voluntary, made the subsequent trial fundamentally unfair under the Fourteenth Amendment.

## Decision

- The Supreme Court affirmed the conviction.
- The Court held the confession was voluntary under the totality of the circumstances and not the product of police coercion.
- The Court held that denying a request to consult counsel during pretrial interrogation does not violate due process automatically; it violates due process only if the denial prejudiced the accused so as to make the subsequent trial lacking in basic fairness.
- On these facts—including Crooker’s age, education, legal training, and demonstrated awareness and exercise of the right to remain silent—the Court found no prejudice amounting to an unfair trial.

## Legal Principles

- A confession’s admissibility under the Fourteenth Amendment depends on voluntariness assessed under the totality of the circumstances.
- Denial of an accused’s request for an opportunity to consult counsel during pretrial proceedings violates due process only if the accused is prejudiced such that the later trial lacks basic fairness.
- Denial of counsel during interrogation is a factor in assessing voluntariness, but (under this decision) it is not a per se ground for exclusion absent a showing of resulting unfairness at trial.
- A defendant’s age, intelligence, education, and demonstrated awareness of the right to remain silent may bear on both voluntariness and whether denial of counsel caused prejudicial unfairness.

## Conclusion

The Court upheld Crooker’s conviction, ruling that his confession was voluntary and that police refusal to permit consultation with counsel during interrogation did not itself violate due process without a showing that the denial prejudiced him and rendered the trial fundamentally unfair.


Crooker v. California, 357 U.S. 433 (1958)