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Townsend v. Sain


The defendant, a confirmed heroin addict, was arrested for his suspected involvement in a murder. When questioned, he denied any involvement. Several hours later the defendant complained of withdrawal sickness. A physician was summoned and administered a dosage of Phenobarbital and hyoscine. The doctor also gave the defendant four or five tablets of Phenobarbital to combat withdrawal symptoms in the future. After the doctor left, an officer and a state’s attorney questioned the defendant. The defendant gave a complete confession to the murder. The defendant later alleged that these drugs had the effect of a “truth serum.” The officers testified they were unaware of the potential effects of the doctor’s treatment.


Whether the confession was voluntarily made?


No. Courts must consider the mental state of a person who makes statements before considering their voluntariness.


Statements are not voluntary if the individual’s will is overborne, or not the product of his rational intellect or free will. The Court stated that coercion could take place either through physical or psychological pressure. Factors that play a role in determining psychological pressure include the mental competency, the youth or inexperience, or the effects drugs have on the suspect. It was immaterial to the Court that the officers did not know of the potential “truth serum” characteristics of the medication administered to the suspect. “Any questioning by officers which in fact produces a confession which is not the product of a free intellect renders that confession inadmissible.”


372 U.S. 293, 83 S. Ct. 745 (1963)

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