Haynes v. Washington 373 U.S. 503 (1963)
HAYNES v. WASHINGTON 373 U.S. 503 (1963)
This was the last of many confessions cases, prior to escobedo v. illinois (1964), in which the Supreme Court decided the voluntariness of a confession by a due process standard. In 1944 the Court had held that due process was violated if the police obtained a confession by continuous interogation while the prisoner was held incommunicado in an inherently coercive situation. Thereafter, however, the Court frequently had deferred to a determination of voluntariness by state courts. Haynes was the first case since 1944 in which the Court revived the standard of inherent coerciveness where the facts showed incommunicado detention and the prisoner was not allowed to call his lawyer. The case foreshadowed Escobedo and miranda v. arizona (1966).
Leonard W. Levy