Haynes v. Washington (1962)
- Docket
- 147
- Decided
- 1962-01-01
Summary
Question: Did the lower court’s admission of the signed confession violate the Due Process Clause of the Fourteenth Amendment? Conclusion: Yes. Justice Arthur J. Goldberg delivered the opinion of the 5-4 majority. The Court held that the Spokane police officers extracted an involuntary confession from Haynes by threatening to hold him without allowing him to contact his family. The Court also held that such tactics were unnecessary because the police had sufficient evidence to charge Haynes with robbery even without the confession. Justice Tom C. Clark wrote a dissent in which he distinguished the officers’ refusal to allow Haynes to call his wife from the voluntariness of the confession. The oral confession that Haynes made within the first ninety minutes of his arrest bolstered Justice Clark’s view that the signed written confession was also voluntary. Justice Clark argued that the officers’ treatment of Haynes did not amount to threats or inducements and that Haynes was an unlikely candidate for coercion given his age, intelligence, and prior criminal record. Justice John M. Harlan, Justice Potter Stewart, and Justice Byron R. White joined in the dissent.