Criminal Law-Confessions-Admission of Illegally Obtained Confession in State Criminal Prosecution Is Harmless Error Not Requiring Reversal of Conviction–People v. Jacobson
Defendant voluntarily admitted that he had murdered his daughter to a social worker, two ambulance attendants, and three police officers sent to investigate the incident. He continued to declare his guilt to these officers after his arrest, on the way to the police station, and at the police station where he was interrogated without the benefit of counsel although he had not waived his right to counsel. All of the confessions-approximately ten-were admitted in evidence at the defendant’s trial over his objection that the two confessions obtained during the interrogation should have been excluded since he had been denied his right to counsel in violation of the sixth and fourteenth amendments. Although these two confessions were unconstitutionally obtained and erroneously admitted, the California Supreme Court held, one judge dissenting, that their admission was a harmless error which did not require a reversal of the conviction.