Leyra v. Denno, 347 U.S. 556 (1954)

The principle that Coerced Confessions in criminal trials violate the Fourteenth Amendment’s guarantee of due process was previously established. This case broke new ground by declaring that evidence gained after a coerced confession could also be found inadmissible. Camilo Leyra was convicted of first-degree murder for killing his elderly parents and sentenced to death, but his convictions were reversed by a state appeals court on the grounds that his confession was coerced. After his parents’ death, Leyra had been interrogated almost continuously for several days on end, and he was physically and emotionally exhausted when a psychiatrist with hypnosis skills managed with threats, assurances of leniency, and leading questions to draw out a confession. Leyra was tried a second time, using as evidence his later confessions to the police and prosecutors. The court let the jury decide as a question of fact whether the later confessions were voluntary or similarly coerced; the jury convicted and again imposed the death penalty, and the New York appeals court affirmed. Leyra challenged the state courts’ decision, charging that his later confessions were also coerced. The Supreme Court agreed, saying that the confessions were closely related in time and circumstances, enough for the later conversations to be tainted by the coerced confession to the psychiatrist. The lower courts left this question to the jury, as the dissenters in the Supreme Court would have done, but the majority thought that the threats to individual liberty were sufficiently serious to warrant the extra protection by invalidating all his confessions.

DAVID D. BURNETT

Cases and Statutes Cited

• Leyra v. Denno, 347 U.S. 556 (1954)

See also Capital Punishment; Capital Punishment: Due Process Limits; Capital Punishment for Felony Murder; Capital Punishment Reversed; Coerced Confessions/ Police Interrogation; Due Process; Due Process of Law (V and XIV); False Confessions; Police Power of the State; Substantive Due Process