The author states that the due process voluntariness test is designed to achieve four interrelated purposes. List and discuss what they are.

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Trustworthiness.

Confessions that result from physical or psychological coercion run the risk that a defendant confessed to avoid or to halt abuse. Statements made under such threats are unreliable and may be false. In Payne v. Arkansas, a nineteen-year-old Black defendant accused of murder was subjected to incommunicado interrogation for three days and confessed following the sheriff's threat to turn him over to a white mob. The Supreme Court ruled that the confession was "coerced and did not constitute an 'expression of free choice'" (Payne v. Arkansas, 356 U.S. 560, 560 [1958]).

Fundamental Fairness.

The use of an involuntary confession against a defendant is fundamentally unfair and compromises the integrity of the courtroom. In White v. Texas, Bob White, an illiterate Black farmhand, was illegally detained and taken to the home of the brother-in-law of a white rape victim. There, he found fifteen or sixteen other Black suspects who also were being illegally detained without charge or access to a lawyer. White then was taken to the jail, where he was detained for six or seven days and was removed at night, taken to the woods, and interrogated. He ultimately signed a confession after having been interrogated most of the night. The Supreme Court ruled that due process prohibits condemning an accused to death through such practices (White v. Texas, 310 U.S. 530 [1940]).

Offensive Police Methods.

Confessions in violation of the Due Process Clause are the product of police tactics that are offensive to fundamental values. In Lynumn v. Illinois, the defendant confessed after three police officers threatened that she would lose her children unless she cooperated and signed a confession. The Supreme Court observed that isolated and inexperienced defendants had "no reason not to believe that the police had ample power to carry out their threats" (Lynumn v. Illinois, 372 U.S. 528, 534 [1963]).

Free Will and Rational Choice.

Confessions violate due process if they are the product of drugs administered by the police or of a suspect's psychological disabilities and if they do not result from free will or rational choice. In Blackburn v. Alabama, a "mentally incompetent" defendant confessed after having been interrogated for eight or nine hours in a small room filled with police officers. Shortly thereafter, he was evaluated as legally insane. Four years later, Jesse Blackburn was declared mentally competent and was prosecuted and convicted of robbery. The Supreme Court held that the chance of Blackburn's four-year-old confession having been the product of "rational choice and free will" was "remote" and that the confession's introduction into evidence was a flagrant abuse of due process (Blackburn v. Alabama, 361 U.S. 199, 208 [1960]).

The voluntariness test is based on the controversial proposition that an involuntary confession should be excluded from evidence, regardless of whether the confession is true or false. We outline in the next section the factors considered by judges in determining whether a confession is voluntary or is the product of coercion.