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.

Spano called Gaspar Bruno, a close friend of his who was 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.

Police escorted Spano to the location where they believed he had disposed of the murder weapon.

The issue was whether police violated Spano's Sixth Amendment right to counsel during interrogation.