Leyra v. Denno

347 U.S. 556 (1954)

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Nature of the Case

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Facts

When Camilo, P’s father, failed to appear at his place of business P, his business partner, and others went to the apartment and found the bodies P's aged parents. The presence on the couple's disarranged breakfast table of a third teacup led them to think that the killer was a welcome guest. P became a suspect. P and others were questioned by the police until about 11 p.m. on the evening of the day the bodies were discovered. On Wednesday, police again questioned P from about 10 in the morning to midnight. Once more, beginning about 9 Thursday morning P was subjected to almost constant police questioning throughout the day and much of the night until about 8:30 Friday morning. P was taken by police to his parents' funeral. After the funeral P was permitted to go to a hotel and sleep an hour and a half. He was returned to the police station at about 5 p.m. on this Friday afternoon. During his absence, a concealed microphone had been installed with wire connections to another room in which the state prosecutor, the police, and possibly some others were stationed to overhear what P might say. When P returned to the questioning room after the funeral, Captain Meenahan introduced him to 'Dr. Helfand,' supposedly to give P medical relief for a sinus problem. Dr. Helfand was a psychiatrist with considerable knowledge of hypnosis. P was left with Dr. Helfand while Captain Meenahan joined the state District Attorney in the nearby listening room. Instead of giving P medical advice and treatment, the psychiatrist by subtle and suggestive questions simply continued the police effort of the past days and nights to induce P to admit his guilt. Time and time and time again the psychiatrist told P how much he wanted to and could help him, how bad it would be for P if he did not confess, how much better he would feel, and how much lighter and easier it would be on him if he would just unburden himself to the doctor. Excerpts from that transcription show that P's answers indicate a mind dazed and bewildered. Time after time P complained about how tired and how sleepy he was and how he could not think. On occasion after occasion, the doctor told P either to open his eyes or to shut his eyes. Many of P's answers were barely audible. On occasions, the doctor informed P that his lips were moving but no sound could be heard. Many times P was asked to speak louder. As time went on, the record indicates that P began to accept the suggestions of the psychiatrist. Dr. Helfand suggested that P had hit his parents with a hammer and after some minutes P agreed that must have been the weapon. After an hour and a half, P, encouraged by the doctor's assurances that he had done no moral wrong and would be let off easily, called for Captain Meenahan. The captain immediately appeared. P confessed and it was admitted against P in this trial. P's business partner was called from an adjoining room. P repeated to his partner in a very brief way some of the things he had told the psychiatrist and the captain. Following this, P was questioned by the two assistant state prosecutors. What purports to be his formal confession was taken down by their stenographer, with a notation that it was given at 10 p.m., several hours after the psychiatrist took P in charge. P was convicted. The New York Court of Appeals held that the admissions made were so clearly the product of 'mental coercion' that their use as evidence was inconsistent with due process of law. On the second appeal, the court held that the subsequent confessions here challenged were properly admitted. The Court of Appeals for the Second Circuit held the same thing. P petitioned for habeas corpus which was initially denied. The Supreme Court granted certiorari.