Monday, December 23, 2013

Jackson v. Denno case brief

Jackson v. Denno case brief summary
378 U.S. 368 (1964)

CASE SYNOPSIS
Petitioner inmate sought review of the judgment of the United States Court of Appeals for the Second Circuit, which affirmed a district court decision that denied petitioner's request for a writ of habeas corpus.

CASE FACTS
The inmate, while he was being treated for a serious gunshot wound, admitted to a robbery and to shooting a police officer. The inmate asserted that his conviction for murder in the state court was invalid because it was founded upon a confession that was not properly determined to be voluntary.

DISCUSSION

  • On appeal, court held that: 
  • (1) the state procedure of submitting the issue of the confession's voluntariness to the jury did not satisfy the Due Process and Fourteenth Amendment requirements; 
  • (2) Stein v. New York, 346 U.S. 156 (1953), which allowed the jury to make the ultimate determination of the confession's voluntary character and its truthfulness, was overruled; and 
  • (3) the inmate was entitled to a hearing in state court to determine the voluntariness of his confession. 
  • It was impossible to discover whether the jury found the confession voluntary and relied upon it or found it involuntary and supposedly ignored it. 
  • Nor was there any indication of how the jury resolved disputes in the evidence concerning the critical facts underlying the coercion issue. 
  • Even if the jury found that the confession was involuntary, it was difficult to prove whether it nevertheless influenced the verdict.

CONCLUSION
The court reversed the denial of the writ of habeas corpus and remanded the case to the district court with instructions to provide a hearing in state court regarding the voluntary nature of the inmate's confession.

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