Leyra v. Denno

Leyra (defendant) was suspected of murdering his parents. Police questioned Leyra for a total of more than 40 hours over three consecutive days, with much of the questioning lasting late into the evenings. On the fourth day, police allowed Leyra to attend his parents’ funeral and then told Leyra, who had a sinus infection, that they would allow him to talk to a doctor. The doctor was actually a psychiatrist trained in hypnosis who, for an hour and a half, asked leading questions, repeatedly admonished Leyra to unburden himself by confessing to the murder, and assured Leyra he would be let off easily if he confessed. Leyra, who was not represented by a lawyer and who repeatedly complained of being tired and unable to think clearly, ultimately confessed to the murder to the psychiatrist and to a police officer. Immediately after Leyra confessed, police called Leyra’s business partner into the room and Leyra repeated part of his confession to his business partner. Leyra was then questioned by two assistant state prosecutors who had their stenographer record Leyra’s formal confession at 10:00 p.m. that evening. Leyra was tried and convicted of murder. The state appellate court reversed the conviction, holding that Leyra’s initial confession had been coerced. At Leyra’s second trial, his confession to the psychiatrist was excluded but his subsequent confessions were admitted into evidence, and he was again convicted. Leyra subsequently petitioned the United States District Court for a writ of habeas corpus and was denied. The United States Supreme Court granted certiorari.