Haynes v. Washington
Citation and Court
373 U.S. 503 (1963) — Supreme Court of the United States
Facts
Haynes was arrested for robbery and held incommunicado by police for 16 hours. During this time he was questioned repeatedly and told he could not call his wife or an attorney until he had confessed. He was also promised he would be allowed to call his family and see an attorney after he signed a statement. Haynes eventually signed a written confession, which was introduced at his robbery trial.
Issue
Does the Due Process Clause require suppression of a confession obtained through prolonged isolation and promises of access to family and counsel contingent on confession?
Holding
Yes; a confession obtained through prolonged isolation, denial of access to family and counsel, and conditional promises that such access would be granted upon confession is involuntary and violates due process.
Rule / Doctrine
The totality of the circumstances governing the obtaining of a confession must show that it was freely and voluntarily made. Prolonged isolation, promises conditioning access to family and counsel on confession, and psychological pressure collectively render a confession involuntary under the Due Process Clause.
Significance
Haynes v. Washington is a pre-Miranda voluntariness case illustrating the cumulative effect of isolation and inducement in rendering a confession coerced. It was decided just three years before Miranda and helped lay the groundwork for the Court’s decision to adopt a categorical prophylactic rule addressing the coercive nature of custodial interrogation.