In People v. La Frana, 122 N.E.2d 583 (Ill. 1954), Illinois' highest court set aside a murder conviction after finding that the confession on which it was based had been coerced. The facts are hauntingly familiar: Midway through a 2-week detention in 1937, defendant, who had not confessed despite days of interrogation, was put in a room with a police captain who
hit him repeatedly with his fists and with a night stick. His hands were then handcuffed behind him and he was blindfolded. A rope was put in between the handcuffs and he was suspended from a door with his hands behind him and his feet almost off the floor. While he was hanging from the door, he was repeatedly struck until he lapsed into unconsciousness. When he lost consciousness he was taken down from the door and when he regained consciousness he would be hung back up on the door and again questioned and struck. After about fifteen minutes of this treatment he agreed to sign a confession. (p.585)
The government having failed its "burden of establishing," "by clear and convincing testimony," "that the injuries were not administered in order to obtain the confession," the court ordered a new trial. And it noted defense counsel's "suggestion" that police had held defendant without charge for another week "to allow time for the injuries received in the beating to heal up, so as to make it more difficult to prove that the beating had occurred." (p.586)
That defense counsel? John Paul Stevens of Chicago, since 1976 a Justice of the U.S. Supreme Court.