Ashcraft v. Tennessee Case Brief
United States Supreme Court
322 U.S. 143 (1944)
ISSUE: Is a confession obtained through constant questioning for over 36 hours without letting D sleep or leave the room valid as against D?
- Mrs. Ashcraft was bludgeoned to death in her car and left on the highway
- No indication in Ashcraft's past or the relationship with his wife that he had any tendency to act violently
- Officers questioned Ashcraft on the day of the murder but found nothing incriminating there
- They then questioned the maid to no avail
- Officers then took Ashcraft into custody and placed him in a jail room with a bright light over his head and questioned him straight for over 36 hours
- On that Monday morning, Ashcraft allegedly confessed and signed a written confession
- Ware convicted of murder, Ashcraft convicted of being an accessory before the fact
- Tenn. Sup. Ct. affirmed convictions
- Not voluntary: If Ashcraft did make a confession, it wasn't voluntary
- Situation was so "inherently coercive" that its very existence is irreconcilable with the possession of mental freedom by a lone suspect against whom its full coercive force is brought to bear
- Constitution stands as a bar against the conviction of any individual in an American court by means of a coerced confession
- Usual standard is that confessions made in custody are admissible unless in fact involuntarily made because of physical violence or fraud or threats
- Prima facie involuntary under those conditions
- But interrogation is not per se unlawful
- SCOTUS has no power to discipline state law enforcement officers or to reverse convictions obtained through conduct of which the justices don't personally approve
- Exceeds bounds of power to say that a 36-hour interrogation is "inherently coercive"
- Custody and examination in general are coercive
- Vountariness shouldn't be a function of time
- With a conflict in testimony between the officers and a D, the court should accept the officers
- Not "secret" because many people participated
- For attacking confessions, it is important to keep the three distinct categories of invalid confessions separate. Ashcraft applies to involuntarily-obtained "confessions" that violate the Due Process Clauses of the Fifth and Fourteenth Amendments.
- The Due Process Clause in the confession context can be violated either through actual physical coercion, i.e., torture, or through interrogation situations that are "inherently coercive" like that in Ashcraft. There is no bright-line test here: you must compare and contrast your fact pattern against that in Ashcraft and Spano to determine if a particular situation qualifies as "inherently coercive" and thus renders any "confession" involuntary.
- It is also important to remember that Ashcraft and Spano are pre-Miranda cases and show how the Supreme Court grappled with how to end the "black police practices" ongoing at the time. These cases set the stage for the broad-sweeping Miranda decision and show why the Court decide Miranda the way it did.