Lynum v. Illinois (1963) Supreme Court


Author: Jack Fruth

Issue: Whether the defendant in this case was coerced at the time she confessed to the crime of selling cannabis.


Facts: Lynum was arrested for the sale of marijuana after police arrested Zeno who agreed to “set someone up for them” in exchange for leniency. Zeno took police to Lynum’s home where he entered her apartment and left in possession of a package of cannabis. The three police officers then entered her home and threatened her that her children would be taken away to live with strangers if she did not cooperate. Both Lynum and the officers attest that the officers told Lynum that her aid would be cut off and that her children would be taken if she did not do as they say and confess. 


Rule: If the defendant’s will was overborn at the time of the confession, they were coerced. See Chambers v. Florida, 309 U.S. 227. A confession must be “the product of a rational intellect and a free will.” Blackburn v. Alabama, 361 U.S. 199, 208. If a defendant gives a confession under coercion, it is inadmissible in court.


Analysis: In terms of determining whether or not Lynum was coerced by the police officers the Court looked at the totality of the circumstances and determined that if someone with no knowledge of the criminal justice system is surrounded by three officers who threaten them with taking their government aid and their children away if they do not “cooperate” with no friend or adviser to turn to then the confession is coerced and thus inadmissible. The Court determined that her confession could not be deemed “the product of a rational intellect and a free will” as stated in Blackburn and thus was a product of coercion.

The State puts forward two arguments for why the Supreme Court should affirm the prior judgment: that Lynum had not prior stated her federal constitutional claim and as such waived it per the rules of Illinois procedure and that the prior ruling did not rest in whole or in part on her confession.

On the first argument, the Court found that while it was true that she did not explicitly assert her claim in the trial court, the Court’s job in this case is to determine whether the judgment was intended to rest on a state ground or whether decision of the federal claim was necessary to the judgment. So that argument does not apply.

On the second, the Court stated that the argument was entirely without merit. Even if there was sufficient evidence for a conviction excluding the coerced confession it is a violation of one’s rights under the Due Process Clause of the Fourteenth Amendment and so vitiates the judgment.


Conclusion: A confession made under such circumstances must be deemed not voluntary but coerced, and as such the case is reversed and remanded to the Supreme Court of Illinois.

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