In late June 1946, in a jail hospital in Chicago, a 17-year-old university student was questioned for two days, then through the whole of a second night. On the third day, at the direction of the State’s Attorney, a psychiatrist gave him sodium pentothal without his consent or his parents'. Officials listened from behind screens while a stenographer took down what he said. Eight years later the Supreme Court of Illinois called what had been done to William Heirens "flagrant violations of his rights." It still let his convictions stand.
That gap, between what the courts condemned and what they allowed, recurs across 70 years of serial cases. Serial cases put more pressure on the interrogation room than almost any other kind of investigation. There are more victims, more families, more departments waiting, and often a suspect who has every reason to talk or every reason to lie. What comes out of that room is then examined by judges, sometimes decades later, under rules that were themselves still being written: on whether a confession was voluntary, on when the Miranda warnings must come, on what a suspect who already has a lawyer may waive, on what a court is to do with a confession that the police themselves helped build.
Seven of them, from Illinois, New York, Washington, Texas, Arizona and California, mark the path. Only one set a rule that a state’s highest court still calls by the defendant’s name. Others drew a line that later courts cite, or exposed a failure that changed how detectives worked. Together they show how the law of confession has been shaped by the men it was applied to.
Heirens was a student at the University of Chicago and, by his own record, a habitual burglar when Chicago police arrested him on June 26, 1946. The police soon linked him to the killings of two women in 1945 and of Suzanne Degnan, a six-year-old girl, in January 1946. The Degnan case had dominated the Chicago press for months.
What the police did over the following days was set down in the 1954 opinion of the Illinois Supreme Court, which reviewed the evidence taken at his post-conviction hearing. He was kept as a bed patient after his arrest. He was questioned at intervals for two days and all through the second night, and his answers were incoherent. On the third day came the sodium pentothal. Under the drug he talked about the crimes and blamed someone he called "George." A doctor who examined him testified that he was "a mentally sick boy," a psychotic schizophrenic and not a malingerer. On June 30 police gave him a lie-detector test, again without his consent. He did not answer the questions.
The press did the rest. Sophia Posnock, in a University of Chicago study of the case, writes that on July 16, 1946, the Chicago Tribune printed a detailed account of how he had committed the killings, presented as his confession, before he had confessed to anything. Other papers reprinted it.
His four lawyers, chosen by Heirens and his parents, then negotiated a plea. A first deal collapsed on July 30, when he told officials and reporters gathered for his confession that he did not remember the crimes. After further talks the State demanded consecutive life terms or a trial on pleas of not guilty. He gave long statements in early August and, on September 4, 1946, pleaded guilty to all three murders and 26 other indictments. There was no trial and no hearing on whether he was competent to plead, Ed McManus wrote in Illinois Issues in 1988. The prosecutor conceded at sentencing, McManus reported, that without the cooperation of defense counsel there would have been "small likelihood of a successful murder prosecution."
Heirens recanted almost at once. When his post-conviction case reached the Illinois Supreme Court, Justice Klingbiel’s opinion of September 23, 1954, did not soften what the police had done. The search of his room, the prolonged questioning and the unauthorized use of the drug and the lie detector were "flagrant violations of his rights," and a conviction obtained by such conduct, the court said, would deny due process. But the pleas had come more than a month later, on the advice of lawyers the court called competent and devoted, and the earlier conduct "had no substantial connection with the pleas of guilty." The judgment was affirmed.
The ruling stated a principle that would outlast it: a coerced statement taints what it produces, but a later guilty plea, entered with counsel, can stand apart from it. Heirens spent the rest of his life on the wrong side of that distinction. A later appeal to the same court went forward in 1964 with no lawyer for him at all. In 1967, after the United States Supreme Court held in another case that such a petitioner was entitled to counsel, the Seventh Circuit held his federal case in abeyance so that the Illinois court could hear his claims with appointed counsel. The convictions survived that too. He died in custody on March 5, 2012, at 83, the longest-serving inmate in Illinois history.
Joseph Baldi was already under indictment when Detective Palmer asked him to come in for questioning shortly after midnight on June 21, 1972. In September 1971 he had been charged with the attempted murder of a Queens police officer. Declared incompetent to stand trial, he had been sent to Mid-Hudson State Hospital and then to Creedmoor State Hospital, which released him in February 1972, the New York Court of Appeals later recorded, without notice to the district attorney or the court. A lawyer still represented him on the pending charge.
Four days earlier, on June 17, Deborah Januszko, 15, had been killed in Queens. On the way to questioning, Baldi raised the old case himself. He told Palmer about the charge involving the police officer and said he had been at Creedmoor. The Court of Appeals noted that Palmer did not follow up and did not ask whether Baldi had a lawyer on that charge. At the station house Baldi was given the Miranda warnings, another detective questioned him, and he confessed to killing the girl. He then went into what the court described as a trance-like state and acted out the killing in pantomime, three times, collapsing after each.
His assigned lawyer, Sidney Sparrow, a practitioner of about 40 years, took a risk in July 1972 that shaped everything after. He arranged two more sessions, on July 7 and July 14, with detectives and two psychiatrists in the room. At the second, a psychiatrist hypnotized Baldi. Across the two sessions Baldi confessed to the Januszko killing, to three other murders and to ten assaults on women. Sparrow later said the interviews were held on the understanding that nothing said would be used against his client; the prosecutor disputed it. A grand jury indicted Baldi for the three other murders on July 18.
At the Huntley hearing, New York’s pretrial test of whether statements to the police may be used, the judge admitted the June 21 confession as voluntary and suppressed the July statements. The confessions to three other murders were never tested in any case that reached an appellate court. A jury convicted Baldi of the 1971 charges in October 1974. In a trial without a jury, a judge rejected his insanity defense and convicted him of murder in the second degree, and he was sentenced on January 16, 1975, to 25 years to life.
The Appellate Division reversed both convictions on the ground that Sparrow had been ineffective. The Court of Appeals, in an opinion by Chief Judge Cooke on October 29, 1981, reversed again. The July interviews were, it said, the "more serious" complaint, and a written agreement with the prosecutor would have been the better course; but the statements had been suppressed and never used. Its central sentence became law: "So long as the evidence, the law, and the circumstances of a particular case, viewed in totality and as of the time of the representation, reveal that the attorney provided meaningful representation, the constitutional requirement will have been met."
One question the court could not settle. Baldi argued, for the first time, that the June 21 confession should have been suppressed because he already had a lawyer on the pending charge and had mentioned that charge to Palmer before questioning began. Citing People v. Bartolomeo, the court said a waiver of the right to counsel made in the absence of a suspect’s lawyer may not be valid, and it sent the case back for the facts to be examined. How that question was finally answered has not been reported.
The standard outlived the case. In 1998, in People v. Benevento, the Court of Appeals called it "the well settled Baldi test." In People v. Stultz in 2004 it wrote that in Baldi "we set the standard for claimed ineffective assistance of trial counsel," explained that the test rested partly on the state constitution, noted that New York had kept it rather than adopt the federal test announced in Strickland v. Washington three years later, and extended it to appellate lawyers. A case born in a station-house confession now governs every claim against a defense lawyer in New York.
Kenneth Bianchi was arrested in Bellingham, Washington, on January 12, 1979, and charged later that month with the murders of two Western Washington University students, Karen Mandic and Diane Wilder. Within days Los Angeles detectives connected him to the series of ten killings of women and girls that had alarmed their county from October 1977 to February 1978.
His interrogation history was unusual because most of it took place in the hands of mental health experts. In March 1979 he changed his plea to not guilty by reason of insanity, and on March 21 a psychologist retained by the defense, John G. Watkins, hypnotized him. A personality calling itself Steve appeared and claimed the killings. A panel of six experts split over whether the personalities were real.
Martin Orne, a University of Pennsylvania psychiatrist and an authority on hypnosis, was called by the prosecution, and his 1984 paper with David F. Dinges and Emily Carota Orne is the most detailed public account of how the claim came apart. Orne remarked to Bianchi that it was "pretty rare for there to be two" personalities; a third, Billy, appeared soon after. When Orne suggested that Bianchi’s lawyer was sitting in the room, Bianchi got up and shook hands with the empty air and asked whether the examiner could see him too, a performance the authors had never seen in a deeply hypnotized subject. The name Steve Walker belonged to a real psychologist whose identity Bianchi had used to obtain diplomas. Orne concluded that "Mr. Bianchi was simulating a multiple personality."
In October 1979, facing a possible death sentence, Bianchi pleaded guilty to the two Bellingham murders and to five in Los Angeles County, and agreed to testify against his adoptive cousin, Angelo Buono. Before Buono’s trial, Superior Court Judge Ronald M. George ruled that Bianchi had faked both his hypnosis and his multiple personalities, and that his testimony was admissible. Bianchi then spent 80 days on the stand contradicting himself, and Buono was convicted of nine murders in November 1983.
Years later Bianchi turned the hypnosis against his own pleas. In a federal habeas petition filed without a lawyer, he argued that his guilty plea had been involuntary, that he had pleaded only after studying police reports and photographs, and that hypnotic suggestion had planted false memories of the crimes. On May 6, 1994, a Ninth Circuit panel affirmed the denial of relief in Bianchi v. Blodgett. It was "not clear that he was ever hypnotized," the court wrote, noting that one examining expert, a specialist in hypnosis, believed he had faked his trances, and it saw no proof that his memories had been engineered. He had pleaded guilty to avoid the death penalty, and his acceptance of guilt was "an exercise of internal reason," not the product of outside coercion. The court cited his lies to police and his confessions to six psychologists among the reasons he would likely not have gone to trial.
The decision is a narrow one, unpublished and listed only in a table of the federal reporter. But it addressed a question that has only grown since: what a court should make of a confession said to be planted by suggestion. Bianchi has kept raising it. The Washington State Standard reported in 2025 that he still claims his confession was the product of hypnosis and maintains he is innocent. On July 14, 2025, Washington’s Indeterminate Sentence Review Board declined to release him.
Henry Lee Lucas was arrested in Montague County, Texas, on June 11, 1983, on a charge that, as a former convict, he possessed a pistol. He began confessing to murders almost at once. He confessed to killing Kate Rich and Becky Powell, cases that had gone unsolved, and he was convicted in both. Then the number grew. By early 1984 he claimed something near 600 killings in more than two dozen states.
A Texas task force formed around him, and officers from across the country came to interview him. Agencies that could not send a detective mailed their questions in; at one stage, the investigator Mike Feary told the Associated Press in 1990, Lucas was confessing to 70 or 80 killings a day this way. The confessions were taken, by and large, in good faith. They were also, in great part, fed. Rod Ponton, who later represented him, told the Big Bend Sentinel in 2019 that Lucas was "the guy telling the big lie, sort of winking at everybody."
The capital case that sent him to death row rested mainly on his own words, the Fifth Circuit later said. The victim was a young woman known for decades only as "Orange Socks," killed on Halloween 1979 and identified in 2019 as Debra Jackson, 23, of Abilene. At a pretrial hearing in Georgetown in February 1984, United Press International reported, Lucas testified that his confession was false and that he had learned the details from a police bulletin. A San Angelo jury convicted him of capital murder anyway, and he was sentenced to death.
The collapse began outside the courts. In April 1985 the Dallas Times Herald published records showing that Lucas had been in other states on the days of killings he had claimed. On April 15, 1985, Attorney General Jim Mattox said his office doubted Lucas had committed all the killings he had confessed to. "There’s no evidence there with the exception of his own confessions," Mattox said, as the Associated Press reported. A McLennan County grand jury in Waco, pressed by the district attorney Vic Feazell, took up both the killings and the handling of the case, D Magazine reported that October. Once out of the custody of the task force, Lucas recanted.
Mattox’s office spent a year on the confessions. Its report, published in April 1986, concluded that Lucas had perpetrated a massive hoax, drawing much of his information from interviews in which officers had shown him crime reports and photographs. On the Orange Socks case the report pointed to work records placing him near Jacksonville, Florida, at the time. In El Paso that same year, a judge threw out his confession in a 1983 murder case at a suppression hearing, and there was no trial, the Big Bend Sentinel reported.
The federal courts would not grant relief on what Lucas called innocence. On January 9, 1998, the Fifth Circuit affirmed the denial of his habeas petition in Lucas v. Johnson. It considered an audit of the Florida work records, an expert’s opinion that his confessions were false, the Attorney General’s report and polygraph results, and held that "a claim of 'actual innocence' is not itself a constitutional claim." The new evidence, the panel said, was "more aptly described as simply corroborative of the alibi defense presented to the jury." Any relief, the court said, lay "if anywhere, in Texas state procedures."
It lay with the governor. In June 1998, on the recommendation of the Board of Pardons and Paroles, Governor George W. Bush commuted the death sentence to life. The jurors, Bush said, "did not and could not have known" of Lucas’s pattern of lying and confessing to crimes, the Associated Press reported. It was the only death sentence he commuted as governor. Lucas died in prison in March 2001. The Orange Socks killing is still an open case in Williamson County.
The Lucas affair produced no landmark ruling. What it changed was practice. After it, Ponton said in 2019, the Texas Rangers stopped relying on confessions alone.
The pattern Lucas exposed did not end with him. In December 2005, after a national television program covered the killing of Georgia Thompson, 19, who had been shot in Tempe, Arizona, that September, a jail inmate in Paducah, Kentucky, told a Crime Stoppers line that a fellow prisoner had bragged about a killing in Tempe. The prisoner, J.M., was a 33-year-old the Phoenix New Times described as a career criminal facing a long sentence for theft and burglary.
In January 2006 a Tempe detective interviewed him in Kentucky, and he confessed. His account contradicted known facts, and the New Times reported that the detective repeatedly supplied him with details. A grand jury indicted him the day after the confession. He was extradited to Arizona and held on a second-degree murder charge.
In July 2006 Phoenix police announced that forensic evidence "definitively" linked Thompson’s death to the series of shootings and assaults that had terrorized south and central Phoenix, The Spokesman-Review reported. On August 3, 2006, the Maricopa County Attorney’s Office dismissed the charge against J.M. County Attorney Andrew Thomas said the man "appears to have made up a story." A month later Phoenix police arrested Mark Goudeau, and in 2011 a jury convicted him of nine counts of first-degree murder, Thompson’s among them.
J.M. testified at that trial. He told the jurors he had never been to Arizona, that he had taken the idea from the television program because he hoped for a lighter sentence in Kentucky, and that "basically everything I said" in the confession was wrong, the New Times reported. The Tempe detective told the jury, in tears, that she had mishandled the investigation. The Arizona Supreme Court affirmed Goudeau’s convictions and nine death sentences in 2016. He maintains his innocence, and a post-conviction petition was pending as of April 2026.
No appellate court ruled on J.M.'s confession, because no case went forward on it. But it was put before a jury as a demonstration of what an interrogation can manufacture, 20 years after the Lucas Report said the same thing at much greater length.
Joel Rifkin was arrested on Long Island on June 28, 1993, and was charged with the murder of Tiffany Bresciani, 22. He confessed that day to 17 killings of women over about four years. His lawyers moved to suppress his statements; a hearing was under way in Mineola in December 1993, and the County Court denied the motion. A Nassau County jury rejected his insanity defense on May 9, 1994, after two hours and ten minutes, and convicted him of murder in the second degree. Guilty pleas in Suffolk, Brooklyn and Queens followed.
On appeal the Appellate Division, Second Department, drew a line. On December 3, 2001, it held that the hearing court should have suppressed what Rifkin said at the time of his arrest. Questions put to him after he had been handcuffed, before he had been read his Miranda rights, were interrogation, the court said, not preliminary questions to clarify what was happening. Because there was no definite break between those questions and the rest of what he said at that time, all of those early statements should have been kept out.
The main confession survived. It was made at the station house about five hours after the arrest, to different officers, after Rifkin had knowingly, intelligently and voluntarily waived his rights, and there had been a definite break in the questioning. Rifkin had not testified at the suppression hearing, and the court saw nothing to show that the confession was the product of the earlier statements. The error at the time of arrest did not require reversal "in light of the otherwise overwhelming evidence of the defendant’s guilt." His other appeals, which argued that the denial of suppression had pushed him into pleading guilty, failed.
The ruling turns on a phrase, a definite break: the line between an unwarned statement that must be excluded and a warned confession that may be used. Rifkin lost his appeal and won the point.
Gerald Parker was in Avenal State Prison in June 1996, an ex-Marine serving time on other convictions, when the Orange County Sheriff’s crime lab matched his DNA to evidence from three of six killings in Orange County in 1978 and 1979. A fourth match followed, to the 1979 case in Tustin in which a woman survived and her full-term unborn daughter did not. For 16 years the man in prison for that case had been the child’s father, another Marine.
On June 14, 1996, two Costa Mesa investigators came to Avenal, advised Parker of his rights and told him of the DNA match. Parker said he could not imagine why he would want to talk about something from so long ago. Later he said "the day is not today" and that he thought he should wait until later. Before they left, the investigators told him that a Tustin investigator also wanted to speak with him. Tarpley, the Tustin detective, advised him of his rights again, and Parker agreed to talk. When Parker asked whether the Costa Mesa detectives were still there and was told they were, he agreed to "get this over with." Over four days and several recorded interviews he admitted all six cases. On June 20, 1996, the father’s convictions were set aside, and he was released that day, according to the National Registry of Exonerations.
Parker was convicted in October 1998 of six counts of first degree murder and sentenced to death. His defense did not dispute his responsibility; it relied on his own statements to argue for second degree murder. On appeal he argued that the confessions should never have been admitted.
The California Supreme Court rejected the claim on June 5, 2017. Parker’s early remarks, it held, were questions about why the officers wanted to talk, not a clear request to remain silent, and he had waived his rights by taking part. His "wait until later" remark was a limited invocation that applied only to the Costa Mesa investigators, not to the Tustin investigator, with whom he agreed to speak after a fresh waiver. Because the crimes predated Proposition 8, which took effect on June 9, 1982, the prosecution had to prove the waiver beyond a reasonable doubt, and the court held it had done so. The United States Supreme Court denied review on February 20, 2018.
The decision is a study in how finely the right to silence can be cut. A suspect may invoke it as to one officer and waive it as to the next, on the same afternoon, in the same room.
Read in order, the seven cases trace the arc of the modern law. In 1946 there was no Miranda, and the Illinois Supreme Court could condemn a drugged, sleepless interrogation of a teenager and still uphold everything that came after it. By 1972 the warnings were routine, and the hard questions had moved to what came around them: a lawyer on another charge whom no one asked about, interviews a defense lawyer arranged himself. By 2001 a New York court was parsing the minutes between handcuffs and warnings, and by 2017 California’s highest court was dividing a single suspect’s silence between two sets of detectives.
The confessions themselves were a different matter. Heirens recanted his and died in prison. Lucas recanted almost all of his, and a governor spared his life over the one that had sent him to death row. J.M. confessed to a killing he could not have committed and was believed long enough to be indicted. Bianchi pleaded guilty and then blamed a hypnotist. Rifkin and Parker confessed in detail, and the courts that cut away parts of what they said kept the rest.
Only Baldi left his name on a rule, and it is a rule about lawyers, not detectives. The interrogation cases left something less tidy: a body of law built one serial case at a time, by judges trying to decide, long after the fact, which of a man’s words could be trusted, and whether it mattered how they had been obtained.
• June 26, 1946: William Heirens arrested in Chicago; questioned over the following days and given sodium pentothal without consent.
• July 16, 1946: The Chicago Tribune prints an account presented as his confession before he has confessed.
• September 4, 1946: Heirens pleads guilty to three murders and 26 other indictments.
• September 23, 1954: The Illinois Supreme Court calls the police conduct "flagrant violations of his rights" but affirms.
• April 11, 1967: The Seventh Circuit holds Heirens’s federal case in abeyance for a hearing with appointed counsel.
• June 21, 1972: Joseph Baldi questioned in Queens and confesses to the Januszko killing.
• July 7 and 14, 1972: Baldi interviewed with his lawyer present, under hypnosis at the second session; confesses to three other murders.
• November 1974: Huntley hearing admits the June confession and suppresses the July statements.
• January 16, 1975: Baldi sentenced to 25 years to life.
• January 12, 1979: Kenneth Bianchi arrested in Bellingham, Washington.
• March 21, 1979: "Steve" first appears under hypnosis.
• October 1979: Bianchi pleads guilty in Washington and Los Angeles County.
• October 29, 1981: People v. Baldi sets New York’s "meaningful representation" standard and sends back the right-to-counsel question.
• November 1981: Judge Ronald M. George rules that Bianchi faked hypnosis and multiple personality.
• June 11, 1983: Henry Lee Lucas arrested in Montague County, Texas, and begins confessing.
• February 1984: Lucas testifies in Georgetown that his Orange Socks confession is false.
• April 1985: The Dallas Times Herald reports the confessions are false; Attorney General Mattox opens a review.
• April 1986: The Attorney General’s report calls the confessions a massive hoax; an El Paso judge throws out a Lucas confession.
• June 28, 1993: Joel Rifkin arrested on Long Island.
• May 6, 1994: Ninth Circuit affirms denial of Bianchi’s habeas petition.
• May 9, 1994: Rifkin convicted in Nassau County.
• June 14 to 18, 1996: Gerald Parker interviewed at Avenal and Corcoran prisons.
• June 20, 1996: The Tustin father’s convictions set aside; he is released.
• January 9, 1998: Fifth Circuit decides Lucas v. Johnson.
• June 11, 1998: People v. Benevento calls Baldi "the well settled Baldi test."
• June 1998: Governor Bush commutes Lucas’s death sentence.
• October 1998: Parker convicted of six counts of first degree murder.
• December 3, 2001: Appellate Division holds Rifkin’s pre-warning statements should have been suppressed and affirms.
• May 4, 2004: People v. Stultz extends the Baldi standard to appellate counsel.
• January 2006: J.M. confesses in Kentucky to the Thompson killing.
• August 3, 2006: The charge against J.M. is dismissed.
• October 31, 2011: Mark Goudeau convicted of nine murders; J.M. testified at the trial.
• March 5, 2012: Heirens dies in custody.
• June 5, 2017: The California Supreme Court affirms Parker’s judgment and rejects the Miranda claim.
• February 20, 2018: U.S. Supreme Court denies Parker’s petition.
• July 14, 2025: Washington’s board declines to release Bianchi.