Lego v. Twomey

Background

A man convicted of armed robbery in Illinois told police he had confessed while in custody. At a pretrial hearing the judge heard conflicting testimony: the defendant said police beat him, and officers denied it. The judge accepted the officers’ account, admitted the confession, and a jury later convicted the defendant. He appealed in state and federal courts, arguing the government should have proved voluntariness beyond a reasonable doubt and that a jury should decide voluntariness.

Reasoning

The Court addressed two questions: what burden of proof the government must meet at a voluntariness hearing, and whether the jury must decide voluntariness. The majority explained that earlier cases require a reliable, judge-led determination that a confession was not coerced but did not set a strict proof standard. The Court held the Constitution requires at least a preponderance of the evidence (more likely than not) to show voluntariness, and that a judge’s finding is constitutionally acceptable. The Court distinguished the high proof rule for guilt (beyond reasonable doubt) as unrelated to admissibility hearings.

Real world impact

The decision keeps the federal constitutional minimum at a preponderance standard and leaves trial judges as the normal decisionmakers on whether a confession can be used at trial. States remain free to adopt stricter rules. The ruling affects criminal defendants, prosecutors, trial judges, and state lawmakers by setting a national baseline for how courts decide challenged confessions.

Dissents or concurrances

A dissent argued the Fifth Amendment’s protection against compelled self-incrimination requires proof beyond a reasonable doubt because the stakes of admitting an involuntary confession justify the higher protective standard.