Monday, December 23, 2013

Lego v. Twomey case brief

Lego v. Twomey case brief summary
404 U.S. 477 (1972)

Petitioner inmate challenged the decision of the United States Court of Appeals for the Seventh Circuit, which denied his petition for a writ of habeas corpus. The inmate maintained that the trial judge should have found his confession voluntary beyond a reasonable doubt before admitting it into evidence or, alternatively, that the voluntariness question should also have been submitted to the jury for its separate consideration.

The evidence introduced at trial included a confession the inmate made to police while he was in custody, which he sought to have suppressed. He did not deny making it but did challenge that he had done so voluntarily. Illinois law provided that a confession challenged as involuntary could be admitted into evidence if, at a hearing outside the presence of the jury, the judge found it voluntary by a preponderance of the evidence. The trial judge conducted a hearing, out of the presence of the jury, at which the inmate testified that police had beaten him, which event was denied by the police. The trial judge ruled the confession admissible, and the inmate's conviction for armed robbery was affirmed in state court. The inmate brought a petition for habeas corpus, which the district court denied.


  • On appeal the court affirmed, holding that when a confession challenged as involuntary was to be used against a defendant at his trial, he was entitled to a reliable and clear-cut determination that the confession was in fact voluntarily rendered, and the prosecution had to prove at least by a preponderance of the evidence that the confession was voluntary. 
  • This standard was satisfied.

The decision that denied habeas relief to the inmate was affirmed.

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