## Facts

- Rogers, charged with murder in Connecticut, was interrogated for several hours without confessing.
- An assistant police chief, within Rogers’s hearing, feigned a telephone call directing officers to prepare to take Rogers’s wife into custody.
- When the assistant chief indicated the wife would actually be taken into custody, Rogers confessed.
- After being jailed and prevented from speaking with others (including an attorney who came to see him), Rogers gave a second confession.
- At trial, Rogers moved to exclude both confessions as involuntary; the trial court admitted them, finding them voluntary while also considering their apparent reliability and consistency with other evidence.
- The Connecticut appellate court affirmed using a similar approach.
- Rogers sought federal habeas relief; the district court denied relief and the Second Circuit affirmed.

## Issues

1. Whether due process permits courts to consider a confession’s apparent truth or reliability when deciding whether it was voluntary and admissible in a state criminal prosecution.
2. Whether the state and lower federal courts applied the correct Fourteenth Amendment standard by focusing on police methods and the suspect’s free will, rather than on the confession’s likely accuracy.

## Decision

- The Supreme Court reversed and remanded.
- The Court held that admissibility of a confession under the Fourteenth Amendment does not turn on whether the confession is likely true.
- The Court concluded that the state courts and lower federal courts used an improper standard by factoring reliability into the voluntariness analysis.
- The case was remanded to allow the State a reasonable time to retry Rogers under the proper standard; otherwise, Rogers was to be discharged.

## Legal Principles

- Due process exclusion of confessions turns on whether the statement was the product of a rational intellect and free will, not on judicial estimates of truth or corroboration.
- Courts must assess the coercive character of police techniques and whether the accused’s will was overborne under the totality of the circumstances.
- A confession cannot be validated by the view that coercive tactics were unlikely to produce a false confession; constitutional limits regulate the methods used to obtain confessions.

## Conclusion

The Court held that due process requires confession admissibility to be determined by the voluntariness of the choice to confess, assessed from police conduct and its effect on the suspect’s free will, and not by whether the resulting confession appears reliable or true; because the lower courts applied a reliability-centered approach, the judgment was reversed and the case remanded for retrial or release.


Rogers v. Richmond, 365 U.S. 534 (1961)