## Facts

- A Washington, D.C. taxi driver picked up two sailors late at night and was directed to the 2200 block of T Place, S.E.
- Upon arrival, one passenger struck the driver on the head and robbed him.
- Investigation linked the suspects to a group of sailors who had been at the Skylark Restaurant that evening.
- Detective Conley interviewed several sailors aboard a Navy ship docked in Washington, D.C.; Heideman denied any knowledge of the robbery.
- Armed Services police later brought Heideman and another sailor (Brennan) to D.C. police headquarters, where Detective Conley questioned them.
- After Brennan implicated Heideman, Heideman confessed that he struck the driver with a sock filled with gravel and took the driver’s wallet; evidence indicated Heideman had been drinking beforehand.
- At trial for robbery, Heideman requested an instruction that intoxication could be considered on whether he was capable of forming the intent to rob; the court refused and instead instructed generally that “drunkenness is no defense to crime.”
- Heideman was convicted.

## Issues

1. Whether Heideman’s confession was inadmissible because it was obtained during an unnecessary delay in presentment following custody, in violation of the rule barring confessions secured during illegal pre-presentment detention.
2. Whether the trial court committed reversible error by refusing to instruct that voluntary intoxication may be considered in determining whether the defendant formed the specific intent to steal required for robbery.

## Decision

- The court held the confession was properly admitted because the period between custody and confession did not constitute an unnecessary delay aimed at extracting a confession.
- The court held the trial court’s intoxication instruction was erroneous because robbery requires specific intent, and the jury should have been instructed—on request and where supported by evidence—that intoxication could negate that intent.
- The conviction was reversed and the case remanded for a new trial.

## Legal Principles

- A confession may be excluded if obtained during an unnecessary delay in presentment; courts evaluate the length and purpose of the delay, including whether police activity was legitimately investigative rather than a holding period to secure a confession.
- Voluntary intoxication is not an excuse for criminal conduct, but it may be considered in determining whether a defendant formed a required specific intent.
- For a specific-intent offense such as robbery (intent to steal), when evidence supports the theory and the defendant requests it, the court must instruct the jury on the relevance of intoxication to the specific-intent element; a flat “drunkenness is no defense” instruction is inadequate and may be misleading.

## Conclusion

The appellate court upheld admission of Heideman’s confession despite a presentment-delay challenge but reversed the robbery conviction because the jury was not properly instructed that intoxication could negate the specific intent to steal, requiring a new trial.


Heideman v. United States, 259 F.2d 943 (D.C. Cir. 1958)