Haley v. Ohio

In Haley v. Ohio (1948) 332 U.S. 596, a 15-year-old boy was arrested at midnight and interrogated for five straight hours by five or six officers in relays of one or two officers at a time. At 5:00 a.m., after being falsely told that two other boys had implicated him, the minor confessed. (Id. at p. 598.) He was then held for three more days before being charged while his mother and an attorney she had retained were rebuffed in attempts to see him. (Ibid.) The Supreme Court found this confession involuntary because "the age of petitioner, the hours when he was grilled, the duration of his quizzing, the fact that he had no friend or counsel to advise him, the callous attitude of the police towards his rights combine to convince us that this was a confession wrung from a child by means which the law should not sanction." (Id. at pp. 600-601.) In that case, the United States Supreme Court held that a 15-year-old's confession was not voluntary when he had been questioned for five straight hours--from midnight to 5:00 a.m.--by five or six officers working in relays and was not advised of his right to remain silent or the right to an attorney until after he confessed. (Haley, at pp. 598, 600-601.) After his confession, he was not permitted to see an attorney for three days and his mother for five days. (Id. at p. 598.) In sum: A 15-year-old boy was informed by officers he did not have to make a statement and that anything he said could be used against him in court. (Id. at p. 598.) Defendant confessed, but the Supreme Court found the timing and duration of the interrogation and the callous attitude of the officers supported a finding that the confession was involuntary despite the advisement of rights. (Id. at pp. 600-601 92 L. Ed. at p. 229.)