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The Vinson Court (1946–53)

Introduction

Did the Vinson Court invalidate confessions obtained by extreme duress?

Yes, the Vinson Court ruled in Watts v. Indiana (1949) that a confession obtained through duress can violate the Due Process Clause. Indiana police charged Robert Watts, a 17-year-old African American, with murder and attempted rape. The police interrogated him for hours at a time for six days. On many days, police would question Watts for eight straight hours. He finally relented and confessed to the crime. His attorney argued that the subsequent conviction should be invalidated because the police officers violated Watts’s due-process rights. The Vinson Court agreed 6–3. “Protracted, systematic, and uncontrolled subjection of an accused to interrogation by the police for the purpose of eliciting disclosures or confessions is subversive of the accusatorial system,” Justice Felix Frankfurter wrote. “It is the inquisitorial system without its safeguards.” Justice William O. Douglas was even blunter in his concurring opinion: “The man was held until he broke…. The procedure breeds coerced confessions. It is the root of the evil.”