Blackburn v. Alabama - 361 U.S. 199 (1960)
U.S. Supreme Court
Blackburn v. Alabama, 361 U.S. 199 (1960)
Blackburn v. Alabama
Argued December 10, 1959
Decided January 11, 1960
361 U.S. 199
After having been discharged from the Armed Forces because of permanent mental disability, and during an unauthorized absence from a Veterans' hospital where he had been classified as 100% "incompetent," petitioner was arrested on a charge of robbery. After eight or nine hours of sustained interrogation in a small room which was at times filled with police officers, he signed a confession written for him by a Deputy Sheriff. Shortly thereafter, he exhibited symptoms of insanity and, after proceedings prescribed by state law, he was found insane and committed to a state mental hospital. Over four years later, he was declared mentally competent to stand trial, and was tried in a state court on the robbery charge. His confession was admitted in evidence over his objection, and he was convicted.
Held: the record clearly establishes that the confession most probably was not the product of any meaningful act of volition, and its use in obtaining petitioner's conviction deprived him of his liberty without due process of law in violation of the Fourteenth Amendment. Pp. 361 U. S. 200-211.
(a) Though it is possible that petitioner confessed during a period of complete mental competence, the evidence here establishes the strongest probability that he was insane and incompetent at the time he allegedly confessed. Pp. 361 U. S. 207-208.
(b) On the record in this case, there was not such a conflict in the evidence as to require this Court to accept the trial judge's conclusion that the confession was voluntary. Pp. 361 U. S. 208-209.
(c) Where the involuntariness of a confession is conclusively demonstrated at any stage of a trial, the defendant is deprived of due process by its use in obtaining his conviction -- even though important evidence concerning the involuntariness of the confession was not introduced until after admission of the confession into evidence and the defendant's counsel did not request reconsideration of that ruling. Pp. 361 U. S. 209-211.
40 Ala.App. ___, 109 So.2d 736, reversed.