The defendant made a series of incriminating statements after being threatened by various government authorities. In a 1967 decision, the Supreme Court rejected the government’s use of those statements from the point of his arrest to written statements he made five days later. The Court held that the “stream of events” was such that the defendant did not make the statements voluntarily. Nonetheless, the government retried the defendant with the use of additional statements the defendant made to an attending physician. One hour after his arrest, the defendant was taken to a hospital for treatment for a gunshot wound, which required two large morphine injections. Within the presence of the attending physician but not the officers, the defendant made several incriminating statements, presumably while under the influence of the morphine injections.
Whether the statements made to the attending physician were made voluntarily?
No. The defendant’s statements were made during the “stream of events” that had been prompted by government coercion.
The Court held that the statements made to the attending physician were a part of the “stream of events” that was involuntary in nature. This “stream of events” was so infected with gross coercion that the Court did not feel comfortable that any statements made under these circumstances were voluntary. The Due Process Clause demands such inherently untrustworthy evidence to be excluded from the government’s use.
408 U.S. 234, 92 S. Ct. 2282 (1972)