Boulden v. Holman (SCOTUS 1969), 394 U.S. 478

Summary

The Court upheld the lower courts’ determination that the petitioner’s confession was voluntary under the constitutional standards applicable before the later interrogation decisions. It nevertheless vacated the Court of Appeals’ judgment and remanded because the record strongly suggested that the death sentence may have been imposed by a jury selected in violation of the governing death-qualification principles, an issue not previously litigated. Justice Harlan, concurring in part and dissenting in part, agreed with remand on jury selection but would also have required review of coercion surrounding an earlier inculpatory statement.

Holding

Voluntariness of the confession. The confession was voluntarily made under the totality of the circumstances, and the district court and Court of Appeals were justified in denying habeas relief on that claim.

Death-qualification of the jury. The death sentence could not constitutionally stand if jurors were excluded on a broader basis than a clear commitment to vote automatically against capital punishment, and the record sufficiently suggested that such broader exclusions occurred to require further proceedings.