Mallory v. United States

Background

A nineteen-year-old man who lived in a basement apartment was arrested the day after a woman was raped in the building’s basement. Police held him at headquarters with other suspects and questioned him several times without telling him he could remain silent or consult a lawyer. After hours of waiting, a polygraph operator examined him in a closed room and, following lengthy questioning, he said he might have done it and then confessed. The police did not take him before a magistrate until the next morning. At trial the signed confession was used, and he was convicted and sentenced to death. The Supreme Court agreed to review whether the delay before taking him to a judicial officer violated Rule 5(a) of the Federal Rules of Criminal Procedure.

Reasoning

The Court focused on whether the arresting officers delayed taking the man before a judge "without unnecessary delay." Relying on prior cases and Rule 5(a), the Court explained that prompt arraignment is meant to prevent secret, coercive interrogation and the "third degree." The officers had access to committing magistrates and could have arraigned him sooner. They interrogated him for hours, used a polygraph, failed to warn him of his rights, and only sought arraignment after he had confessed. The Court held that this extended delay made the confession improperly obtained and reversed the conviction.

Real world impact

The decision reinforces that police must promptly bring arrested people before a judicial officer and not use prolonged questioning at headquarters to obtain confessions. Confessions obtained after such unlawful delay are likely to be excluded from evidence. Because most jurisdictions have similar rules, the ruling reaffirms national safeguards against coercive interrogation practices.