## Facts

- Charles Townsend, an Illinois state prisoner sentenced to death for murder, challenged the admission of his confession.
- After arrest, Townsend (a heroin addict) experienced withdrawal and requested medical assistance.
- A police physician administered drugs identified as phenobarbital and hyoscine (scopolamine).
- While under the influence of the medication, Townsend confessed; the confession was admitted at trial over objection.
- In federal habeas proceedings, Townsend alleged the drugs had “truth serum” properties that overbore his will, making the confession involuntary under the Fourteenth Amendment.
- He also alleged that material facts about the drug and its effects were concealed during the state admissibility hearing.
- The State conceded in federal court that disputes existed about whether the drug functioned as a “truth serum,” its effects, and whether relevant facts were concealed.

## Issues

1. Whether a federal district court may deny a state prisoner’s habeas petition without an evidentiary hearing when the petition alleges disputed facts that, if proven, would show a confession was constitutionally involuntary.
2. Under what circumstances federal habeas courts must conduct a plenary evidentiary hearing rather than rely solely on the state-court record.

## Decision

- The Supreme Court reversed the Seventh Circuit and remanded.
- The Court held the district court erred by denying habeas relief without a plenary evidentiary hearing.
- The Court did not decide whether the confession was actually drug-induced or involuntary; it required factual development in federal court.

## Legal Principles

- If a state prisoner’s habeas petition alleges facts that, if proved, would entitle the prisoner to relief, the federal habeas court has authority to receive evidence and determine the facts.
- A federal evidentiary hearing is required when material facts are in dispute and any of the following conditions apply:
  - the merits of the factual dispute were not resolved in state proceedings;
  - the state factual determination is not fairly supported by the record as a whole;
  - the state factfinding procedure was not adequate to provide a full and fair hearing;
  - there is a substantial allegation of newly discovered evidence;
  - the material facts were not adequately developed in the state hearing; or
  - the state trier of fact did not provide a full and fair fact hearing for any reason.
- A confession is constitutionally inadmissible if obtained when the defendant’s will was overborne; this includes confessions elicited under the influence of drugs that have “truth serum” properties.

## Conclusion

The Court required a federal evidentiary hearing because Townsend’s habeas petition raised unresolved, material factual disputes about whether his confession was involuntary due to drug effects and whether the state process failed to develop the relevant facts fully and fairly.


Townsend v. Sain, 372 U.S. 293 (1963)