Facts
- Robert A. Watts was arrested in Indianapolis on suspicion of murder and held for roughly six days without arraignment.
- During detention, he was denied access to counsel, family, or friends and was not advised of constitutional rights.
- He was kept much of the time in solitary confinement in a cell with no bed or chair, requiring him to sleep on the floor.
- Police questioned Watts repeatedly, using relays of officers and extending interrogations late into the night.
- Watts confessed during this period; the confession was admitted at his state murder trial over objection.
- He was convicted of first-degree murder and sentenced to life imprisonment; the Indiana Supreme Court affirmed.
Issues
- Whether admitting a confession obtained after prolonged incommunicado detention, solitary confinement, and relay questioning, without arraignment or access to counsel or friends, violates the Fourteenth Amendment Due Process Clause.
- Whether voluntariness under due process turns on the total circumstances of detention and interrogation, even absent proof of physical torture.
Decision
- The Supreme Court reversed the Indiana Supreme Court and set aside the conviction.
- The Court held that the confession was involuntary under the Due Process Clause because it was extracted through sustained police pressure during prolonged, isolating detention.
- The judgment was supported by separate opinions; no single rationale commanded a majority, but a majority agreed the confession’s use denied due process.
Legal Principles
- The Fourteenth Amendment Due Process Clause forbids a state from using a confession that is not the product of a free and unconstrained choice.
- Voluntariness is assessed under the totality of circumstances, including the duration of detention, conditions of confinement, and the nature and persistence of interrogation.
- Prolonged incommunicado detention, isolation, and late-night relay questioning can render a confession involuntary even without evidence of overt physical violence.
- Due process review focuses on the legality and fairness of police methods, not merely the apparent reliability of the confession.
Conclusion
Because Watts’s confession was obtained after nearly a week of isolating, unarraigned detention and sustained relay interrogation without access to counsel or supportive contacts, its admission at trial violated due process, requiring reversal of his conviction.