Sunday, November 3, 2013

Lisenba v. California case brief

Lisenba v. California case brief summary
314 U.S. 219 (1941)

Petitioner, who was convicted of murder, appealed an order of the Supreme Court of California, which denied his petition for habeas corpus to respondent State of California. Petitioner argued that the confession admitted against him at trial was the result of the coercive conduct of the police during his interrogation and that the confession violated his due process rights under U.S. Constitutional Amendment XIV.

Petitioner argued that the police officers of respondent State of California denied his right to due process under U.S. Constitutional Amendment XIV by extorting his confession by coercive means. After a hearing, the trial judge admitted the confession, and the jury convicted petitioner of murder. The state appellate courts affirmed the conviction and denied the writ of habeas corpus. The court acknowledged that when the officers failed to produce petitioner before a magistrate, detained him for days, assaulted him, and denied him access to counsel, they violated state law. However, these illegal acts did not determine whether a due process violation had occurred.

The issue was whether the use of the confession resulted in an unfair trial.

  • The purpose of excluding involuntary confessions was to exclude false evidence, but the aim of due process was to exclude any evidence the use of which would be fundamentally unfair. 
  • The evidence about how petitioner's confession was obtained was conflicting, and the court could not find that the lower court's findings were erroneous. 
  • The record supported a finding that petitioner was not influenced by the officers' acts. 
  • The court thus affirmed.


The court affirmed the state supreme court's decision to deny the writ of habeas corpus. Although the behavior of the police officers of respondent State of California in procuring the confession of petitioner fell within the definition of criminal conduct under state law, the trial court and jury found that the confessions were voluntary. The court's review of the record did not contradict these findings.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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