## Facts

- Don Richard Lego was prosecuted in Illinois for armed robbery.
- Before trial, Lego moved to suppress a police-obtained confession as coerced, alleging police beatings; officers denied coercion.
- After a suppression hearing with conflicting testimony, the trial judge found the confession voluntary and admitted it under Illinois’s preponderance-of-the-evidence standard.
- The confession was introduced at trial, and Lego was convicted.
- The trial court instructed the jury on the prosecution’s burden to prove guilt, but did not instruct that the jury must find the confession voluntary before considering it.
- Illinois courts affirmed the conviction.
- Lego sought federal habeas relief, arguing the Constitution required (1) proof beyond a reasonable doubt of voluntariness as a condition of admissibility and (2) a jury determination of voluntariness after the judge’s ruling.

## Issues

1. Whether due process requires the prosecution to prove the voluntariness of a confession beyond a reasonable doubt as a prerequisite to admissibility.
2. Whether the Constitution requires the jury to independently determine voluntariness after the judge has ruled the confession admissible.

## Decision

- The Supreme Court affirmed the denial of habeas relief.
- The Court held that a preponderance-of-the-evidence standard for judicial determinations of voluntariness is constitutionally sufficient.
- The Court held there is no federal constitutional requirement that the voluntariness issue, once decided by the judge, must also be submitted to the jury for a separate determination.

## Legal Principles

- Due process permits a state to admit a confession if the trial judge finds it voluntary by a preponderance of the evidence.
- The reasonable-doubt standard required for proving criminal guilt does not constitutionally extend to the preliminary admissibility determination of confession voluntariness.
- Determining the admissibility of evidence, including voluntariness under a separate hearing procedure, is a judicial function; the Constitution does not require a second, independent jury ruling on voluntariness.

## Conclusion

The Court upheld state procedures allowing judges to admit confessions upon a preponderance showing of voluntariness and rejected claims that due process or the jury-trial guarantee requires proof beyond a reasonable doubt or a separate jury determination of voluntariness.


Lego v. Twomey, 404 U.S. 477 (1972)