Spano v. New York
Encyclopedia
Spano v. New York, 360 U.S. 315 (1959) represented the Supreme Court
's movement away from the amorphous voluntariness standard for determining whether police violated due process
standards when eliciting confessions and towards the modern rule in Miranda v. Arizona
. In Spano, the Court focused less on factors such as meals provided to the accused and more on whether the accused had access to legal counsel.
Spano was questioned continuously for several hours and was told he could not consult with his attorney. The police provided him with dinner during his first night of questioning. The following day, Spano was transferred to another police station where questioning continued. He was again denied assistance of counsel. Bruno, upon police instructions, told Spano that he could get into trouble if Spano did not confess, although Bruno's job was not really in jeopardy. Bruno approached Spano four times before Spano gave a statement; each time questioning had resumed, Spano requested assistance of counsel. Police escorted Spano to the location where they believed he had disposed of the murder weapon. While searching for the weapon, Spano confessed.
The issue was whether police violated Spano's Sixth Amendment
right to counsel during interrogation. The Court did not reach the Sixth Amendment question, however, because they held that the use of the confession was inconsistent with the Fourteenth Amendment
and fundamental fairness. The Court identified six factors that together constituted police misconduct:
The Court held that the interrogation violated Spano's 14th Amendment due process rights because Spano's confession was not voluntary.
The two concurring opinions emphasized Spano's right to counsel.
. Even though the majority opinion used the traditional voluntariness analysis, the concurring opinions indicated that a person had a constitutional right to counsel, if that counsel had been retained, once the person was formally charged by indictment or information. The majority opinion did not preclude the right-to-counsel argument expressed in the concurring opinions.
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
's movement away from the amorphous voluntariness standard for determining whether police violated due process
Due process
Due process is the legal code that the state must venerate all of the legal rights that are owed to a person under the principle. Due process balances the power of the state law of the land and thus protects individual persons from it...
standards when eliciting confessions and towards the modern rule in Miranda v. Arizona
Miranda v. Arizona
Miranda v. Arizona, , was a landmark 5–4 decision of the United States Supreme Court. The Court held that both inculpatory and exculpatory statements made in response to interrogation by a defendant in police custody will be admissible at trial only if the prosecution can show that the defendant...
. In Spano, the Court focused less on factors such as meals provided to the accused and more on whether the accused had access to legal counsel.
Case
Spano was an immigrant in his mid-twenties with a junior high school education. He shot a person after a bar fight. He fled the crime scene and was indicted for murder while he was in hiding. Spano called Gaspar Bruno, a close friend of his training to become a police officer. Spano told Bruno that the deceased had injured him, and that he intended to get a lawyer and turn himself in to law enforcement. Bruno relayed the information to his superiors. Spano, along with his newly appointed attorney, turned himself in the day following his conversation with Bruno.Spano was questioned continuously for several hours and was told he could not consult with his attorney. The police provided him with dinner during his first night of questioning. The following day, Spano was transferred to another police station where questioning continued. He was again denied assistance of counsel. Bruno, upon police instructions, told Spano that he could get into trouble if Spano did not confess, although Bruno's job was not really in jeopardy. Bruno approached Spano four times before Spano gave a statement; each time questioning had resumed, Spano requested assistance of counsel. Police escorted Spano to the location where they believed he had disposed of the murder weapon. While searching for the weapon, Spano confessed.
The issue was whether police violated Spano's Sixth Amendment
Sixth Amendment to the United States Constitution
The Sixth Amendment to the United States Constitution is the part of the United States Bill of Rights which sets forth rights related to criminal prosecutions...
right to counsel during interrogation. The Court did not reach the Sixth Amendment question, however, because they held that the use of the confession was inconsistent with the Fourteenth Amendment
Fourteenth Amendment to the United States Constitution
The Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments.Its Citizenship Clause provides a broad definition of citizenship that overruled the Dred Scott v...
and fundamental fairness. The Court identified six factors that together constituted police misconduct:
- Spano was relatively young and inexperienced in the criminal justice system.
- Spano was subjected to leading questions and did not make a narrative statement to police.
- He was questioned incessantly and through the night.
- Police persisted questioning him even though he said his attorney advised him to remain silent.
- Police ignored his request to contact his attorney.
- The officers used his close friend, Bruno, to manipulate him.
The Court held that the interrogation violated Spano's 14th Amendment due process rights because Spano's confession was not voluntary.
The two concurring opinions emphasized Spano's right to counsel.
Effects of the decision
Spano opened the door for Miranda v. ArizonaMiranda v. Arizona
Miranda v. Arizona, , was a landmark 5–4 decision of the United States Supreme Court. The Court held that both inculpatory and exculpatory statements made in response to interrogation by a defendant in police custody will be admissible at trial only if the prosecution can show that the defendant...
. Even though the majority opinion used the traditional voluntariness analysis, the concurring opinions indicated that a person had a constitutional right to counsel, if that counsel had been retained, once the person was formally charged by indictment or information. The majority opinion did not preclude the right-to-counsel argument expressed in the concurring opinions.