Facts
- Nathan Jackson was convicted in New York of first-degree murder and sentenced to death after a police officer was shot during events following a hotel robbery.
- Shortly after arriving at a hospital with gunshot wounds, Jackson made an inculpatory statement to a detective admitting the robbery and shooting.
- Several hours later, after receiving narcotic and sedative medication and having suffered significant blood loss, Jackson gave a second, recorded statement to an assistant district attorney admitting he shot the officer and fired first.
- At trial, both statements were admitted into evidence.
- Jackson testified that his hospital statements were obtained while he was in severe pain and under pressure, and he gave an account that differed in material respects from the confessions.
- Under New York’s procedure, the trial judge admitted the confessions upon finding a “fair question” of voluntariness and instructed the jury to disregard them if involuntary, but otherwise to consider their truth and weight.
- The jury returned a general verdict of guilt, leaving no explicit determination of whether it found the confessions voluntary.
- After state review, Jackson sought federal habeas relief, arguing both that his confession was involuntary and that New York’s procedure for deciding voluntariness was unconstitutional.
Issues
- Whether due process permits a procedure in which the trial judge admits a confession when voluntariness presents a “fair question” and the same jury deciding guilt also decides voluntariness through a general verdict.
- Whether due process requires a clear, reliable, and independent determination of voluntariness before a confession may be used as evidence of guilt.
Decision
- The Supreme Court held that New York’s procedure for determining confession voluntariness violated the Due Process Clause of the Fourteenth Amendment.
- The Court ruled that due process requires a fair hearing and a reliable determination of voluntariness that is not affected by the confession’s truth or by the factfinder’s view of guilt.
- The Court overruled Stein v. New York, which had approved the challenged procedure.
- The Court ordered that Jackson receive a state-court voluntariness hearing before a body other than the jury that determined guilt; a new trial was not automatically required.
- If, after a constitutionally adequate hearing, the confession is found voluntary, the conviction may stand; if found involuntary, Jackson is entitled to appropriate relief, potentially including a new trial without the confession.
Legal Principles
- A conviction based in whole or in part on a coerced confession violates due process, regardless of the confession’s truth and even if other evidence could support the conviction.
- Due process requires an adequate and reliable determination of voluntariness, including resolution of disputed facts bearing on coercion, before a confession is submitted as evidence of guilt.
- A procedure that leaves voluntariness to the same jury that decides guilt, without a separate and explicit determination of voluntariness, is constitutionally insufficient because the jury’s assessment of guilt may affect its voluntariness decision and a general verdict does not reveal how the confession was treated.
- States retain flexibility in structuring the required determination, but the process must provide an independent, clear-cut adjudication of voluntariness (commonly through a separate hearing).
Conclusion
The Court invalidated New York’s jury-centered method for resolving confession voluntariness and held that due process requires an independent and reliable determination of voluntariness before a confession may be considered in deciding guilt.