Lynumn v. Illinois, 372 U.S. 528 (1963)

Beatrice Lynumn was a tenant in an apartment building known to James Zeno. Zeno, a twice-convicted felon, had been caught by Cook County police officers with narcotics in his possession. To better his situation, Zeno agreed to ‘‘finger’’ another person who dealt drugs. Lynumn was called and offered a payment of money owed to her by Zeno. After Zeno entered the building and returned with a small amount of marijuana, the police officers entered the building and searched the Lynumn’s apartment finding drugs. On being arrested, Lynumn, who was unfamiliar with criminal procedure, denied giving Zeno anything. But under pressure from the officers and Zeno and threatened with the possible loss of her children, Lynumn confessed that she gave the marijuana to Zeno. Lynumn was convicted and sentenced to ten years. Her conviction was upheld by the Illinois Supreme Court.

The U.S. Supreme Court’s opinion reversed the lower courts. The Court stated that Lynumn’s confession was not ‘‘voluntary,’’ as required by the Fifth Amendment, because of the totality of the circumstances. Lynumn was surrounded by three officers and a convicted felon, unfamiliar with criminal procedures, and threatened with the loss of her children. This rendered her confession involuntary and thus inadmissible. A coerced confession obtained by a promise the suspect will not lose custody of her children and will keep her welfare benefits was not voluntary. MARTHE´

L. MCCOY

See also Coerced Confessions/Police Interrogations; Miranda Warning