## 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

1. 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.
2. 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.


Watts v. Indiana, 338 U.S. 49 (1949)