Constitutional Law – Due Process – Coerced Confessions and the Stein Case

Stein v. People of State of New York, a coerced confession case decided by the Supreme Court last June, at first suggests some rather startling propositions about the effect of a denial of procedural due process. Since Brown v. Mississippi in 1936 it has been well settled that the admission of a coerced confession into evidence in a state criminal proceeding contravenes the due process guaranty of the Fourteenth Amendment. In the confession cases subsequently considered by the Supreme Court it has been consistently held that the admission of an extorted confession vitiates the entire proceeding and renders the conviction void. Moreover, the cases have indicated that where a coerced confession has been used in evidence the conviction must fall even though there is evidence apart from the confession sufficient to sustain the jury’s verdict. Indeed, this is in accord with the general constitutional doctrine that a denial of procedural due process is jurisdictional in nature, resulting in a nugatory proceeding irrespective of the weight of evidence pointing to the guilt of the accused.

However, the majority of the Court in the Stein case held that even though a coerced confession may have been admitted into evidence, the conviction would be sustained because there was other evidence sufficient to warrant a finding of guilty by the jury. The purpose of this comment is to examine the implications of this decision and to attempt to determine to what extent it overrules well-settled constitutional principles.