Ashcraft v. State of Tennessee

In 1940, in Chambers v. Florida the Supreme Court acknowledged that psychological coercion, as well as physical torture, could produce involuntary confessions. The use of such confessions violated the Due Process Clause of the Fourteenth Amendment. In later decisions, such as Ashcraft v. State of Tennessee, the Court acknowledged that some situations were so inherently coercive that the confessions produced by them were inadmissible in court. The factor determining admissibility was voluntariness, not veracity. The Court did not reject Ashcraft's confession because it was unreliable. In fact, evidence suggested that Ashcraft was responsible for his wife's murder. But the 36 hours of questioning was unacceptable police conduct, and the Court sought to deter this behavior. The Court used this "police conduct" rationale to condemn and deter abusive police interrogation methods. The Court excluded confessions obtained by offensive means regardless of how credible the confession might be. The "voluntary" test, however, was difficult to apply because the terms "voluntariness" and "coercion" were not used analytically, but merely as conclusions. Not until the mid 1960s did the Court develop a definite rule regarding the admissibility of prolonged questioning of a suspect in custody. This rule emphasized the right to counsel and the new requirements were based on the Fifth and Sixth Amendments.