The Supreme Court announced in 1936 that under certain circumstances the admission of a confession into evidence by a state court could amount to a denial of due process as guaranteed by the Fourteenth Amendment. Since that time there has been an increasing number of appeals seeking reversal of a conviction upon that ground and an expansion by the Court of the types of factual situations which will render a confession inadmissible. That this expansion reached its apex with the case of Watts v. Indiana and companion cases decided in 1949 appears probable in the light of a recent denial of certiorari on facts similar to the Watts case. Considering this factor and also the intervening change in court personnel, it seems appropriate to re-examine the issue of admissibility of confessions under the Fourteenth Amendment.
Harold G. Christensen S.Ed.,
CONSTITUTIONAL LAW-DUE PROCESS OF LAW-ADMISSIBILITY OF CONFESSIONS UNDER THE FOURTEENTH AMENDMENT,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol50/iss4/5