Townsend v. Sain

Police interrogated Charles Townsend (defendant) about the robbery and murder of Jack Boone. Townsend provided no incriminating information until after he began to experience severe heroin-withdrawal symptoms during his interrogation. Eventually, a doctor gave Townsend phenobarbital and hyoscine. Shortly after, Townsend confessed to murdering Boone. Townsend moved to suppress his confession as involuntary, and the trial court denied the motion without explanation. Townsend again attacked his confession’s circumstances and reliability at trial. Townsend testified that the doctor’s drugs had made Townsend black out and that when Townsend awoke, he discovered that he had confessed. At trial, the doctor who administered Townsend’s medications and Townsend’s expert witness heavily disputed the potential effects of combining phenobarbital and hyoscine. Neither witness mentioned that hyoscine is familiarly known as “truth serum.” Besides Townsend’s confession, very little evidence linked Townsend to Boone’s murder. The jury convicted Townsend of murder and sentenced him to death. Townsend thoroughly exhausted his state remedies. Townsend filed a federal habeas petition, alleging in part that the government withheld information at trial regarding the “truth serum” properties of hyoscine. The federal district court declined to hold an evidentiary hearing, finding that the state-court record was sufficient to determine that Townsend voluntarily confessed. The appellate court affirmed, and the United States Supreme Court granted certiorari.