Jackson v. Denno (1963)
- Docket
- 62
- Decided
- 1963-01-01
- Category
- General
Summary
Question: Is the New York procedure governing the admissibility of allegedly involuntary confessions constitutional? Conclusion: No. Justice Byron R. White delivered the opinion of the 6-3 majority. The Court held that the New York procedure did not allow for a reliable determination of whether or not the confessions were voluntary. Because the judge does not rule on the issue and the jury only reports on the ultimate question of guilt or innocence, there is no way to determine whether the jury found he confession voluntary. Without this information, there is no way to ensure that the defendant’s rights are protected. The Court also held that, in cases where there is insufficient evidence to find the defendant guilty without the confession, the jury will take the defendant’s guilt into account when considering the voluntariness of the confession. Because there are issues of fact in question, the Court remanded the case to that state courts, rather than the federal court. Justice Hugo L. Black wrote an opinion concurring in part and dissenting in part. He argued that the question of whether a confession is voluntary should remain in the hands of the jury, per the New York procedure. Allowing the judge to rule on the voluntariness of the statement prior to the jury could only distort the jury’s findings and downgrade the value of the trial by jury. He agreed with the majority that the statements in this case were involuntary. Justice Tom C. Clark joined in the opinion concurring part and dissenting in part. In his dissenting opinion, Justice Tom C. Clark argued that the New York procedure was not in question because no objection was raised when the evidence was introduced in trial. Because this objection was not raised, it was improper for the majority to rule on the issue. He also argued that the question of voluntariness of a statement is an issue for the jury to consider, not a trial judge. Justice John M. Harlan wrote a dissent and argued that issues such as the voluntariness of a confession should be decided by the jury, as the jury trial is the cornerstone of the US judicial system. He also argued that the majority’s opinion was inconsistent with previous rulings that upheld that primacy of the jury. Additionally, Justice Harlan wrote that limits should only be placed on the states’ ability to prevent criminal conduct when their actions infringe on “rights fundamental to a decent society,” which he argues this issue does not. Justice Tom C. Clark and Justice Potter Stewart joined in the dissent.