Rochin v. California Case Brief

Why is the case important?

The Appellant, Rochin (Appellant), alleged that the Due Process Clause had been violated when police forced him to vomit two capsules that he had swallowed.

Facts of the case

Rochin swallowed drug capsules to dispose of evidence. The police pummeled him and jumped on his stomach in a vain effort to make him throw up. They took him to a hospital where a doctor was instructed by the police officers to administer an emetic by forceably passing a tube into Rochin’s stomach. He vomited the capules and was convicted on the basis of the evidence produced from his vomit.

Question

Can the police forcibly extract evidence from a person’s stomach?

Answer

No. The Due Process Clause of the Fourteenth Amendment of the United States Constitution (Constitution) prohibits the use of coerced confessions. There is no distinction between a coerced verbal confession and a coerced physical confession. To hold otherwise would be to sanction police brutality in obtaining physical evidence, while prohibiting police brutality in obtaining a verbal confession.

Conclusion

The Court found no distinction between a verbal confession extracted by physical abuse and a confession wrested from defendant’s body by physical abuse. Moreover, the Court found that the police officers’ conduct, by illegally violating defendant’s privacy, struggling to open his mouth, and forcibly extracting his stomach’s contents, shocked the conscience. The Court ruled that the coerced evidence was inadmissible under the Due Process Clause of the Fourteenth Amendment.

  • Case Brief: 1952
  • Petitioner: Rochin
  • Respondent: California
  • Decided by: Vinson Court

Citation: 342 US 165 (1952)
Argued: Oct 16, 1951
Decided: Jan 2, 1952