Lyons v. State of Oklahoma
Decided on June 5, 1944; 322 US 596


I. ISSUES II. CASE SUMMARY III. AMICI CURIAE IV. DECISION V. WIN OR LOSS?

I. ISSUES:

A. Issues Discussed: Due process

B. Legal Question Presented:

 Was "the second confession [in this case] given under such circumstances that its use as evidence at the trial constitutes a violation of the due process clause of the Fourteenth Amendment, which requires that state criminal proceedings 'shall be consistent with the fundamental principles of liberty and justice?'"

II. CASE SUMMARY:

A. Background:

 Appellant was arrested for the murder of a husband and wife and their four year old son. "Immediately after his arrest there was an interrogation of about two hours at the jail. After he had been in jail eleven days he was again questioned, this time in the county prosecutor's office... While petitioner was competently represented before and at the trial, counsel was not supplied him until after his preliminary examination, which was subsequent to the confessions... There is testimony by Lyons of physical abuse by the police officers at the time of his arrest and first interrogation on January 11th."

Eleven days after his first interrogation on January 11th, the second interrogation, which is objected to by Appellant, occurred. "Again the evidence of assault is conflicting. Eleven or twelve officials were in and out of the prosecutor's small office during the night. Lyons says that he again suffered assault. Denials of violence were made by all the participants accused by Lyons (...) It is not disputed that the inquiry continued until two-thirty in the morning before an oral confession was obtained and that a pan of the victims' bones was placed in Lyon's lap by his interrogators to bring about his confession...

After the oral confession in the early morning hours of January 23, Lyons was taken to the scene of the crime and subjected to further questioning about the instruments which were used to commit the murders. He was returned to the jail about eight-thirty A.M. and left there until early afternoon. After that the prisoner was taken to a nearby town of Antlers, Oklahoma. Later in the day a deputy sheriff and a private citizen took the petitioner to the penitentiary. There, sometime between eight and eleven o'clock on that same evening, the petitioner signed the second confession.

The judge in accordance with Oklahoma practice and, after hearing evidence from the prosecution and the defense in the absence of the jury, first passed favorably upon its admissibility as a matter of law... and then, after witnesses testified before the jury as to the voluntary character of the confession, submitted the guilt or innocence of the defendant to the jury under a full instruction, approved by the Criminal Court of Appeals... The instruction did not specifically cover the defendant's contention, embodied in a requested instruction, that the second confession sprang from the fear engendered by the treatment he had received at Hugo." The Appellant was then convicted by the jury for murder, the judgment was affirmed by the Criminal Court of Appeals.

On certiorari the US Supreme Court affirmed the judgment.

B. Counsel of Record:
ACLU Side
(Petitioner/Appellant)
Opposing Side
(Respondent/Appellee)
Unavailable Unavailable
C. The Arguments:
ACLU Side
(Petitioner/Appellant)
Opposing Side
(Respondent/Appellee)
Unavailable Unavailable
III. AMICI CURIAE:
ACLU Side
(Petitioner/Appellant)
Opposing Side
(Respondent/Appellee)
Mr. Thurgood Marshall, of Baltimore, Md., for petitioner. Mr. Sam H. Lattimore, of Oklahoma City, Okl., for respondent.
IV. THE SUPREME COURT'S DECISION:

"The voluntary or involuntary character of a confession is determined by a conclusion as to whether the accused, at the time he confesses, is in possession of 'mental freedom' to confess to or deny a suspected participation in a crime...

Where there is a dispute as to whether the acts which are charged to be coercive actually occurred, or where different inferences may fairly be drawn from admitted facts, the trial judge and the jury are not only in a better position to appraise the truth or falsity of the defendant's assertions from the demeanor of the witnesses but the legal duty is upon them to make the decision... The Oklahoma Criminal Court of Appeals in the present case decided that the evidence would justify a determination that the effect of a prior coercion was dissipated before the second confession and we agree...

The Fourteenth Amendment is a protection against criminal trials in state courts conducted in such a manner as amounts to a disregard of 'that fundamental fairness essential to the very concept of justice,' and in a way that 'necessarily prevent(s) a fair trial...' The Fourteenth Amendment does not provide review of mere error in jury verdicts, even though the error concerns the voluntary character of a confession. We cannot say that an inference of guilt based in part upon Lyons' McAlester confession is so illogical and unreasonable as to deny the petitioner a fair trial."

The US Supreme Court affirmed the judgment of the Criminal Court of Appeals.

Justice Vote: 3 Pro vs. 6 Con

  • Murphy, F.Pro (Wrote dissenting opinion)
  • Rutledge, W. Pro (Joined dissenting opinion)
  • Black, H. Pro (Joined dissenting opinion)
  • Reed, S. Con (Wrote majority opinion)
  • Douglas, W. Con (Wrote concurring opinion)
  • Stone, H. Con (Joined majority opinion)
  • Jackson, R. Con ((Joined majority opinion)
  • Roberts, O. Con (Joined majority opinion)
  • Frankfurter, F. Con (Joined majority opinion)
  • V. A WIN OR LOSS FOR THE ACLU?

    The ACLU, as amicus curiae, urged reversal of the judgment Criminal Court of Appeals; the Supreme Court affirmed in a 3-6 vote, giving the ACLU an apparent loss.