In Ashcraft v. Tennessee (1944) 322 U.S. 143, 153-154, the Supreme Court found a confession was coerced where the defendant was questioned relentlessly for a period of 36 hours, without any break, by a tag team of officers and lawyers. In Chambers v. Florida (1940) 309 U.S. 227, 238-240, the Supreme Court held that a confession was coerced where the Black defendant was arrested and held for five days without any charges being brought, was questioned in a small room with numerous officers present, as well as White citizens from the community, and where the confession resulted after an all-night session in which the defendant was deprived of sleep. Culombe v. Connecticut (1961) 367 U.S. 568 involved a mentally handicapped defendant who (1) was detained illegally for a four-day period; (2) was questioned periodically while he was detained; and (3) never was advised of his right to counsel but who, nevertheless, requested counsel and was ignored. Finally, in Reck v. Pate (1961) 367 U.S. 433, the mentally handicapped defendant (1) had no prior involvement with the police; (2) was held for eight days without charges being brought; (3) was questioned repeatedly despite being physically ill and hospitalized on at least two occasions; (4) was put on display at the police station; and (5) was denied proper food, clothing, counsel, or any contact with friends or family.