Spano v. New York Case Brief

Why is the case important?

An individual was accused of murdering another individual after the victim took his money from a bar.

Facts of the case

“On January 27, 1957, Vincent Joseph Spano was involved in a bar fight with Frank Palermo, Jr. Palermo knocked Spano to the ground and kicked him in the head multiple times. Later that night, Spano acquired a gun, found Palermo, and killed him. On February 1, 1957, a grand jury indicted Spano for first-degree murder and a warrant was issued for his arrest. Two days later, Spano called Gaspar Bruno, a longtime friend of his who was enrolled in the police academy. During that conversation, Spano told Bruno that Palermo had been beaten up in a fight, he was dazed, and he shot at Palermo. The next day, Spano turned himself in but refused to answer officers’ questions. The police questioned him for several hours before they brought in Spano’s friend Bruno to play on their friendship in order to convince Spano to confess, which he eventually did.The confession was admitted into evidence at trial, and the jury was instructed to consider it only if it was found to be voluntary. The jury found Spano guilty and sentenced him to death. The New York Court of Appeals affirmed.”

Question

Whether the confession was properly admitted into evidence under the Fourteenth Amendment?

Answer

“The conviction cannot stand. As in all such cases, we are forced to resolve a conflict between two fundamental interests of society

  • its interest in prompt and efficient law enforcement, and its interest in preventing the rights of its individual members from being abridged by unconstitutional methods of law enforcement.
    Petitioner was a foreign-born young man of 25 with no past history of law violation or of subjection to official interrogation, at least insofar as the record shows. He had progressed only one-half year into high school and the record indicates that he had a history of emotional instability. He did not make a narrative statement, but was subject to the leading questions of a skillful prosecutor in a question and answer confession. He was subjected to questioning not by a few men, but by many.
  • “”>

    Conclusion

    “The Supreme Court of the United States found that Spano’s involuntary confession had been wrongly admitted into evidence over appropriate objection at trial. The confession was inconsistent with U.S. Const. amend. XIV under traditional principles. Spano was subjected to questioning by several men for nearly eight hours. The questioning was not conducted during normal business hours, but began in early evening, continued into the night, and did not bear fruition until morning. The questioners persisted in the face of Spano’s repeated refusals to answer on the advice of his attorney. The Court found another factor that deserved mentioning was the use of Spano’s “”childhood friend,”” now a police officer, to play upon his sympathy. The Court concluded that Spano’s will was overcome by official pressure, fatigue, and sympathy falsely aroused in a post-indictment setting. The police were only concerned in securing a statement from Spano on which they could convict him.”

    • Case Brief: 1959
    • Petitioner: Vincent Joseph Spano
    • Respondent: State of New York
    • Decided by: Warren Court

    Citation: 360 US 315 (1959)
    Argued: Apr 27, 1959
    Decided: Jun 22, 1959
    Granted Dec 15, 1958