Jefferson County’s Landmark U.S. Supreme Court Case

In May of 1958, the U.S. Supreme Court upheld the due process protection against coerced confessions in the pivotal court case, Payne vs. Arkansas, which originated from a court case in Pine Bluff. Image Credit:   https://theappellatelawfirm.com In May of 1958, the U.S. Supreme Court upheld the due process protection against coerced confessions in the pivotal court case, Payne vs. Arkansas. The petitioner, Frank Andrew Payne, a 19-year-old African American with a fifth-grade education, was convicted of first-degree murder and sentenced to death by electrocution for the murder of  J. M. Robertson, an elderly retail lumber dealer in the city of Pine Bluff, Arkansas. Robertson was found dead or dying in his office from severe head wounds. There was more than $450 missing from the cash drawer, and Payne, who Robertson had recently hired, was the main suspect. Wiley A. Branton, an Arkansas civil rights lawyer, appealed to the Supreme Court on Payne’s behalf, arguing that his conviction, largely based on a confession, was obtained through coercion, violating his constitutional rights under the Fourteenth Amendment. The Supreme Court then investigated to determine whether  Payne's interrogation met the due process standards mandated by the Constitution. The Court specifically focused on Payne’s rights to remain silent, to counsel, and to be free from coercion during the confession process, which were violated at any point during his arrest and interrogation.  Payne was questioned at home by police without being arrested on October 4, the night of Robertson's murder. At around 11:00 a.m. on October 5, he was arrested without a warrant and placed in the city jail. Arkansas law states that when an arrest is made without a warrant, the person arrested has the right to prompt access to a magistrate. The magistrate then states the charges, asks whether the accused would like counsel, and allows the accused to seek counsel. Though Payne was arrested without a warrant, he was never taken before a magistrate or notified of his rights to remain silent and seek legal counsel. Payne was held incommunicado without any charge against him from the time of his arrest at 11 a.m. on October 5 until after his confession on the afternoon of October 7. No counsel, friends, or family members were allowed to visit him. Members of his family tried to see him, but they were turned away, as officers stated that they did not "make it a practice of letting anyone talk to [prisoners] while they are being questioned." Though Payne asked for permission to make a telephone call, the request was denied.  Payne received his first meal at 1:00 p.m. on October 6 after 25 hours in police custody. After being transported to Little Rock to take a lie detector test administered by the state police, he finally received two sandwiches, shoes, and socks for his bare feet. He did not eat again until the next morning, meaning he had only received two meals even after being in police custody for more than 40 hours.  In addition, according to Payne, his confession was induced after the following interaction with the chief of police. "I was locked up upstairs, and Chief Norman Young came up [about 1 p.m. on October 7] and told me that I had not told him all of the story -- he said that there were 30 or 40 people outside that wanted to get me, and he said if I would come in and tell him the truth that he would probably keep them from coming in." Chief Young had moved Payne to his private office for questioning. Soon after, Payne agreed to make a statement. Almost immediately, there was a knock on the door. Young stepped outside, and left the door ajar, allowing Payne to hear him say, "He is fixing to confess now,” and “he would like to have me alone." Payne had no idea if it was just one person or the 30 or 40 people that “wanted to get him.” Young reentered his office and began questioning Payne, who immediately confessed that he had committed the crime. Young then admitted Sergeant Halsell of the State Police and Sheriff Norton, who further questioned Payne. Soon after, a court reporter and several businessmen called into the room. At the beginning of the trial, Branton moved to suppress the confession because it was obtained by coercion heavily influenced by the threat of mob violence. When asked during the private motion hearing, Payne stated “I was more than afraid because Chief Norman Young had already told me that there were 30 or 40 people outside, and the way he stated it, if I hadn't, if I didn't make the confession, that he would let them in, from the conversation, from the way that he told me." The trial judge overruled the motion to suppress the confession, admitting the confession into evidence. The court instructed the jury to disregard the confession if they thought it was not made voluntarily. The jury returned a guilty verdict of first-degree murder with a penalty of death by electrocution.  At the end of its investigation, The Supreme Court found that Payne’s confession was indeed coerced. The Supreme Court cited that Payne was denied swift access to a magistrate following an arrest without a warrant, notice of his rights to remain silent and to have legal counsel, and fair treatment during interrogation,  revealed by his prolonged isolation, denial of food, and the implied threats of mob violence. As a result, admitting the confession into evidence went against the "expression of free choice” because of the illegal manner in which the confession was obtained. They also found that the confession violated the Due Process Clause of the Fourteenth Amendment. Consequently, the Supreme Court reversed the judgment of the Arkansas Supreme Court, which had previously affirmed Payne's conviction, and remanded the case back to an Arkansas court. Sources:  https://supreme.justia.com - Payne v. Arkansas, 356 U.S. 560 (1958) https://www.casemine.com - Payne v. Arkansas: Reinforcing Due Process Protections Against Coerced Confessions Written by: Ninfa O. Barnard