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The case of Ashcraft et al. v. Tennessee involved the murder of Mrs. Ashcraft and the conviction of two petitioners, Ware and Ashcraft. Both petitioners claimed that their confessions were obtained through coercion and violated their Fourteenth Amendment rights. The Supreme Court found that neither the trial court nor the Tennessee Supreme Court made a factual determination that the confessions were "freely and voluntarily made." The court finds that Ashcraft's confession was obtained through coercive means and violates Constitutional due process. Confessions obtained through such means cannot be used as evidence in court. Ashcraft and Ware were jointly tried and convicted for murder, but since Ashcraft's conviction has been reversed, it is unclear whether Ware's conviction would have been sustained. The US Supreme Court has sent Ware's case back to the Tennessee Supreme Court to reconsider his conviction in light of the reversal of Ashcraft's conviction.
Forced confessions violate fundamental fairness, and confessions made after arrest are not truly voluntary. The court considers various factors to determine the admissibility of a confession, and confessions obtained through physical abuse or torture are generally considered involuntary. The Court has introduced a new doctrine for determining the admissibility of confessions, which raises questions about the admissibility of Ware's confession. Lack of tangible clues pointing to guilt is irrelevant to the question of the voluntary or involuntary character of statements to officers. The Constitution does not prohibit inherently coercive pressure to disclose information about a crime, as long as it does not exceed the individual's ability to resist and refuse to answer. The Court condemns violent or brutal treatment or threats by prosecutors, but acknowledges that detention and examination can be inherently coercive.
The Tennessee courts properly determined that Ashcraft's confessions were voluntary and allowed them to be presented to the jury. The Supreme Court questioned whether it was constitutional to leave the determination of voluntariness solely to the jury, but Tennessee provided double safeguards of a preliminary trial by the judge and a final determination by the jury, meeting the test for due process. Justices Holmes, Roberts, and Frankfurter argue that states should not be prevented from protecting their citizens from crime by misusing the due process clause.
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