CHAMBERS v. FLORIDA 309 U.S. 227 (1940)

Chambers was the first coerced confession case to come before the Court since the landmark decision in brown v. mississippi (1936). In Brown, the physical torture being uncontested, the state had relied mainly on the point that the right against self-incrimination did not apply to state proceedings. In Chambers, before the state supreme court finally affirmed the convictions it had twice reversed so that juries could determine whether the confessions had been freely and voluntarily made, and the record showed no physical coercion. Moreover, the state contested the jurisdiction of the Supreme Court to review the judgments, arguing that there was no question of federal law to be denied. However, the Supreme Court, in an eloquent opinion by Justice hugo l. black, unanimously asserted jurisdiction and reversed the state court.

Black rejected the state's jurisdictional argument, declaring that the Supreme Court could determine for itself whether the confessions had been obtained by means that violated the constitutional guarantee of due process of law. Reviewing the facts Black found that the black prisoners, having been arrested on suspicion without warrant, had been imprisoned in a mob-dominated environment, held incommunicado, and interrogated over five days and through a night until they abandoned their disclaimers of guilt and "confessed." police interrogation had continued until the prosecutor got what he wanted. On the basis of these facts Black wrote a stirring explanation of the relation between due process and free government, concluding that courts in our constitutional system stand "as havens of refuge for those who might otherwise suffer because they are helpless, weak, outnumbered, or because they are non-conforming victims of prejudice.…" Applying the exclusionary rule of Brown, the Court held that psychological as well as physical torture violated due process.

Leonard W. Levy
(1986)