Lisenba v. California, 314 U.S. 219 (1941), was a case in which the United States Supreme Court upheld the criminal conviction and death sentence imposed upon a man who confessed to murder after being detained for more than 24 hours, slapped and deprived of sleep and food.
The majority of the Supreme Court found that the police officers violated state law when they illegally detained Lisenba for two days, assaulted him, and denied him access to counsel.
However, the court found that these illegal acts did not themselves constitute a due process violation, asserting that Lisenba had confessed of his own free will after being confronted with the testimony of an accomplice, not directly after the interrogation.
He exhibited a self-possession, a coolness, and an acumen throughout his questioning, and at his trial, which negatives the view that he had so lost his freedom of action that the statements made were not his but were the result of the deprivation of his free choice to admit, to deny, or to refuse to answer.Justice Hugo Black, joined by Justice William O. Douglas, used the facts of the case to decide in favor of the petitioner, noting the case's factual similarities to Chambers v. Florida, a landmark 1940 case (argued before the court by future Justice Thurgood Marshall on behalf of the petitioner) in which the court ruled that confessions compelled by police through duress are inadmissible at trial.
Black's dissenting opinion describes the circumstances of Lisenba's confession:Suspecting the defendant of murder they entered his home on Sunday, April 19, 1936, at 9 a.m.