The abhorrence of society to the use of involuntary confessions," he wrote for the Court in 1959, "does not turn alone on their inherent untrustworthiness.

That is, where there is distasteful or inhumane conduct that would amount to an involuntary confession.

His first conviction was reversed in a state court proceeding because his involuntary confession was improperly admitted in his first trial.

In one of them, the jury asked the judge to explain the difference between a voluntary and an involuntary confession.

The admission of an involuntary confession is a "trial error," similar in both degree and kind to the erroneous admission of other types of evidence.

Nor can it be said that the admission of an involuntary confession is the type of error which "transcends the criminal process."

He described the 1966 ruling as a "pragmatic" effort by the Supreme Court to protect the pre-existing right against involuntary confessions.

Reasoning that a harmless error analysis was inappropriate in the case of involuntary confessions, the court ordered a new trial.

While the Supreme Court had ruled as early as 1897 against involuntary confessions, it was in 1937 that things really started to change.

The Miranda decision attempts to eliminate suspect ignorance as a contributing factor to involuntary confessions.